In general
If—
(i)#
paragraph (1) does not apply to a distribution by reason of paragraph (2)(D), and
(ii)#
the series of payments under such paragraph are subsequently modified (other than by reason of death or disability)—
(I) before the close of the 5-year period beginning on the date of the first payment and after the taxpayer attains age 59½, or
(II) before the taxpayer attains age 59½,
(ii)(I)#
before the close of the 5-year period beginning on the date of the first payment and after the taxpayer attains age 59½, or
(ii)(II)#
before the taxpayer attains age 59½,
the taxpayer’s tax for the 1st taxable year in which such modification occurs shall be increased by an amount, determined under regulations, equal to the tax which (but for paragraph (2)(D)) would have been imposed, plus interest for the deferral period (within the meaning of subsection (t)(4)(B)).