Which of the following distributions from a profit-sharing plan would not be subject to the 10% early withdrawal penalty, assuming the participant has not attained age 59? a. A distribution made from an IRA that was established 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 a participant who lost his right leg above the knee in a car accident. c. A distribution to pay for costs of higher education for a participant's 18 year-old daughter. d. A distribution made to the participant after she separated from service at age 57.