So I have two of these Partnership Penalty notices (2011 Returns) - which can be abated using the 84-35 Proc - less than 10 Partners etc, but had to wait to make sure the Partners Form 1040 were filed this last week (10/15/2012) - before I respond.
Seems like IRS is on Automated Generating Notices for these Penalties, and only the "Second Notice" being issued is a "Notice of Intent to Seize Your Property"
Very Intimidating -
I don't get it - when if they (IRS) reviews the Form 1065 being filed, IRS can readily see that there are less than 10 partners, and should know that 9 times out of 10 - someone will contact IRS to abate under Rev Proc 84-35
More phone time!
Sandy
Seems like IRS is on Automated Generating Notices for these Penalties, and only the "Second Notice" being issued is a "Notice of Intent to Seize Your Property"
Very Intimidating -
I don't get it - when if they (IRS) reviews the Form 1065 being filed, IRS can readily see that there are less than 10 partners, and should know that 9 times out of 10 - someone will contact IRS to abate under Rev Proc 84-35
More phone time!
Sandy
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