NQ Annuity 10% Pre 59.5 Exception Question ??

Hello,

I posted the excerpt below of what the rule is for someone that takes a prior to age 59.5 early withdrawl from a NQ annuity and the contributions to the annuity were all prior to 8/14/82 ( Pre TEFRA ) NQ annuity.

The question is:

Is all of the withdrawl NOT subject to the 10% penalty as all of the gain came from the contributions that were made Pre TEFRA, 8/14/82 ?

I would say yes to that question. I am getting confused with the word "attributable" and "allocable".

Confirming it means if the money was put in prior to 8/14/82 Pre TEFRA, if you withdraw it to
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