IRS Penalty Abatement: Strategy, Eligibility, and Representation

This course provides tax professionals with a comprehensive framework for identifying, analyzing, and resolving IRS penalties, including Failure-to-File, Failure-to-Pay, Failure-to-Deposit, and accuracy-related penalties. Participants will evaluate eligibility for First-Time Abatement, reasonable cause, and other relief provisions under applicable IRC sections and Treasury Regulations, while developing defensible abatement requests supported by proper documentation and strategy. The course also incorporates recent case law, including Kwong v. United States, highlighting statute of limitations considerations, application of IRC §§6402 and 7508A, and the limits of penalty challenges and refund claims.