Sam $($age $45)$ is considering an IRA withdrawal, but his tax preparer tells him it would be taxable in the year it is received unless it qualifies for an exception. All the following are allowable exceptions except.

Select one:

a$.$ Withdrawals of contributions by the due date of the return

b$.$ Withdrawals for hardships

c$.$ A rollover from one IRA into another

d$.$ Withdrawals of excess contributions by the due date of the return