The distribution is taxable but is not subject to the 10% additional tax on early distributions. She reports the income in equal amounts in 2020, 2021, and 2022 unless she chooses to report it all in 2020. Form 8915-E is used to report coronavirus distributions. Here’s some material from IRS Pub. 590-B.
Taxation of Qualified Coronavirus-Related Distributions
Qualified coronavirus-related distributions are included in income in equal amounts over 3 years. However, if you elect, you can include the entire distribution in your income in the year it was received.
Qualified coronavirus-related distributions aren’t subject to the 10% additional tax (or the additional 25% tax for certain distributions from SIMPLE IRAs) on early distributions from qualified retirement plans (including IRAs). Also, if you are receiving substantially equal periodic payments from a qualified retirement plan, the receipt of a qualified coronavirus-related distribution from that plan won’t be treated as a change in those substantially equal payments merely because of the qualified coronavirus-related distribution. However, any distributions you received in excess of the $100,000 qualified coronavirus-related distribution limit may be subject to the additional tax on early distributions.
Note. If a qualified taxpayer dies before the full taxable amount of the coronavirus-related distribution has been included in gross income (or repaid), the remainder must be included in income for the tax year of the taxpayer’s death.