Substantial Understatement of tax penalty- Any success getting it waived?

[Taxadvisor VA]

TP did not receive 1099R for an early distribution of an IRA account. Therefore, information was not provided to me and a CP2000 was just received.
Penalty > $1,000 and I'm wondering if IRS would accept an explanation that information was not mailed to them ( I know it's lame) but more importantly that they have always filed accurate returns indicative of their willingness to comply with the Income Tax Laws of the US.

Has anybody had any success in doing this?

Thanks in advance,

Taxadvisor VA

[MDEA]

Penalties

Use first time abatement. See previous post.

[New York Enrolled Agent]

Use first time abatement. See previous post.

I need to disagree.

The FTA does not apply to an accuracy related penalty under §6662.

VA - depending on the facts & circumstances, you might be able to have the penalty abated for reasonable cause. Review the IRM at 20.1.1.3.2

[FEDUKE404]

And then. . .

TP did not receive 1099R for an early distribution of an IRA account. . .

Is this right up there with "The dog ate my 1099R" ??

FE

[Taxadvisor VA]

Penalties-MDEA

Use first time abatement. See previous post.

Thank you for taking the time to answer me.
Best Regards,

Taxadvisor VA

[Taxadvisor VA]

NY EA Response

I need to disagree.

The FTA does not apply to an accuracy related penalty under §6662.

VA - depending on the facts & circumstances, you might be able to have the penalty abated for reasonable cause. Review the IRM at 20.1.1.3.2

Thank you for taking the time to respond to my question.
I especially appreciate the references that you use.
Best Regards,

Taxadvisor VA

[taxea]

IMO the first thing you need to do is obtain a document that verifies the 1099 was not issued. Then you need to determine why the client didn't get it. Now you are ready to argue the abatement with the IRS.