Penalty Abatement

 

Recognizing that most taxpayers are law abiding citizens, but may have been prevented from timely filing their tax returns or timely paying their taxes due to unforeseen circumstance, Congress has enacted numerous provisions within the Internal Revenue Code providing for abatement of penalties if the taxpayer establishes reasonable cause.  From an administrative practice perspective, the Internal Revenue Service has adopted a Consolidated Penalty Policy Handbook, which includes numerous avenues for obtaining an abatement of penalties on the basis of reasonable cause.  We are frequently asked to assist clients in obtaining an abatement of delinquency penalties when reasonable cause exists for doing so.