Reasonable Cause for Penalty Abatement 20.1.1.1.3.pdf - WARNING All Information provided below has been published by the Internal Revenue Service which

Reasonable Cause for Penalty Abatement 20.1.1.1.3.pdf -...

This preview shows page 1 - 3 out of 61 pages.

WARNING: All Information provided below has been published by the Internal Revenue Service which is solely responsible for the accuracy of the content. The following is provided solely as general information and is not intended nor should it be utilized as legal advice of any kind. Federal Tax law and its application to any situation can be extraordinarily complex and is highly dependent upon the facts and circumstances of the individual Taxpayer. Every Taxpayer’s situation is different and the application of IRS rules and procedures can vary significantly from one Taxpayer to another. Positions taken by the IRS in its publications are not necessarily the final word on the subject matter. Statutes and Regulations, as well as Administrative and Judicial decisions and other events can greatly impact the application of any IRS position stated below. Pursuant to requirements related to practice before the Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter. IRS Programs and Rules change often and the information on this site may have changed. Telephone to discuss your particular situation, any changes in IRS Programs, Rules and Procedures and how IRS Programs, Rules and Procedures might apply to you and to your individual situation. 20.1.1 3 Relief From Penalties 1. Generally, relief from penalties falls into four separate categories. They are: • Reasonable Cause - Statutory Exceptions - Administrative Waivers - Correction of Service Error. 2. Appeals may recommend the abatement or nonassertion of a penalty based on these four criteria as well as "Hazards of Litigation." 3. This chapter discusses each of these categories and the related criteria. Also, see section 1.3 of LEM 20.1. 4. In the interest of fairness, the Service will consider requests for penalty relief received from third parties, including requests from representatives without an authorized power of attorney. While information may be accepted, NO taxpayer information may be discussed with a third party, unless a power of attorney or other acceptable authorization is secured in writing from the taxpayer. See 1.3 of LEM 20.1. 1. If additional information is needed, contact the taxpayer or the taxpayer's authorized representative. 2. If the validity of the request is questionable, contact the taxpayer. 3. In all cases involving third party requests for penalty relief, advise the taxpayer of the request and the action taken.
Image of page 1
20.1.1.3.1 Reasonable Cause 1. Reasonable cause is based on all the facts and circumstances in each situation and allows the Service to provide relief from a penalty that would otherwise be assessed. Reasonable cause relief is generally granted when the taxpayer exercises ordinary business care and prudence in determining their tax obligations but is unable to comply with those obligations.
Image of page 2
Image of page 3

You've reached the end of your free preview.

Want to read all 61 pages?

  • Spring '08
  • Schuster

What students are saying

  • Left Quote Icon

    As a current student on this bumpy collegiate pathway, I stumbled upon Course Hero, where I can find study resources for nearly all my courses, get online help from tutors 24/7, and even share my old projects, papers, and lecture notes with other students.

    Student Picture

    Kiran Temple University Fox School of Business ‘17, Course Hero Intern

  • Left Quote Icon

    I cannot even describe how much Course Hero helped me this summer. It’s truly become something I can always rely on and help me. In the end, I was not only able to survive summer classes, but I was able to thrive thanks to Course Hero.

    Student Picture

    Dana University of Pennsylvania ‘17, Course Hero Intern

  • Left Quote Icon

    The ability to access any university’s resources through Course Hero proved invaluable in my case. I was behind on Tulane coursework and actually used UCLA’s materials to help me move forward and get everything together on time.

    Student Picture

    Jill Tulane University ‘16, Course Hero Intern

Stuck? We have tutors online 24/7 who can help you get unstuck.
A+ icon
Ask Expert Tutors You can ask You can ask You can ask (will expire )
Answers in as fast as 15 minutes
A+ icon
Ask Expert Tutors