I realize that abatement of IRS penalties depends upon facts and circumstances. However, how does the IRS really know when it should abate some of a taxpayer's penalties as opposed to all of a taxpayer's penalties? For example, are there a certain number of reasonable cause exceptions that would probably have to be met and stated before the IRS might abate all of a taxpayer's penalties in relation to their tax return that was due a couple of years ago along with tax owed versus just some of a taxpayer's penalties in relation to their tax return?
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I don't recall ever having seen a partial abatement of penalties. Everything I've ever tried reusulted in all-or-nothing on penalties."The only function of economic forecasting is to make astrology look respectful" - John Kenneth Galbraith -
My understanding
The way I understand things, the IRS first looks to your filing and paying record. If you have no penalties in the past 3 years they will just drop the penalty if asked to do so. If your record is not clean then you have to deal with reasonable cause. From my experience, reasonable cause is a touogh sell.Comment
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