Jerry, who is age 56, was just called into the President's office at Napa Sunrise, Inc. He just learned that his position has been eliminated in the recent reorganization. While he is devastated, he thinks he may attempt to retire and work at his golf game. Jerry has a retirement plan at Napa Sunrise which permits a lump sum distribution. Can he take the distribution and avoid the early withdrawal penalty since he is separating from service at age 56?