Abating Penalties and Writing Letters to the IRS and States

2 IRS CE/CTEC/NASBA CPE*

Practitioners regularly inherit clients carrying penalties whose abateability turns on which authority actually applies — statutory, regulatory, administrative, or case law. Reasonable cause, first-time abatement, Rev. Proc. 84-35 for small partnerships, and §6751(b) supervisory-approval challenges all live in different lanes. Picking the wrong path, or stacking them in the wrong order, wastes the client's best shot at relief.

This program walks through the major civil penalties — §6651, §6662, §6663, §6038/6038D, §6677, §6698 — and the framework for abating each. Coverage includes the Boyle line (and the Eleventh Circuit's 2023 extension to e-filing in Lee), Neonatology reliance standards, the current state of §6038 penalty litigation after the DC Circuit's Farhy reversal and the Tax Court's reaffirmations in Mukhi and Safdieh, IRS's revised handling of automatic Form 3520 foreign-gift assessments, and the §10.29 conflict question when the practitioner's own conduct is part of the reasonable cause story. Mechanics — Form 843 versus PPS phone request, FTA sequencing with reasonable cause — are covered.

For experienced EAs, CPAs, and tax attorneys who handle representation work and want a current, framework-driven approach to penalty abatement.

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*Self-Study recording not available for NASBA CPE credit.

IRS Program #: 7Q3WU-T-00900-26
CTEC Course #: 6248-CE-00248