Which of the following distributions from a profit-sharing plan would be subject to the 10% early withdrawal penalty, assuming the participant has not attained age 59?

a. A distribution for a 50-year old spouse under a Qualified Domestic Relations Order (QDRO) pursuant to a divorce from the participant in the profit-sharing plan.

b. A distribution from the plan to pay income taxes due to a federal tax levy.

c. A distribution to pay for costs of higher education for a participants 18-year-old daughter.

d. A distribution made to the participant after he/she separated from service at age 57.