Which of the following distributions from a qualified plan would be subject to the 10% penalty tax for premature distributions?

a. Annual payments of $10,000 made over the employee's lifetime, beginning after the date of separation from service.

b. An in-service distribution of $100,000 to an employee who is 55 years of age.

c. Payments to a former spouse under a qualified domestic relations order.

d. Payments resulting from an employee's disability prior to age 59-1/2.