Construction Industry Conference - Virtual-Examples

Examples - penalty protest and request

Pdf Summary

The document is a collection of sample letters and protests seeking IRS penalty abatement for individuals, partnerships, and businesses. The requests challenge penalties for late filing or payment, late payroll-tax deposits, estimated-tax underpayments, and accuracy-related errors. Several also dispute IRS examination decisions or request an Appeals conference.<br /><br />The examples present circumstances offered as reasonable cause, including:<br /><br />- A small partnership’s claim to qualify for relief under Revenue Procedure 84-35.<br />- Corporate officers’ alleged theft and embezzlement, which concealed unpaid payroll taxes.<br />- Serious illness, disability, death, or family medical emergencies.<br />- Employee or tax-preparer misconduct, including unfiled returns, altered records, or inaccurate filings.<br />- Financial hardship caused by business losses, delayed government reimbursements, economic downturns, litigation, or unexpected expenses.<br />- Reliance on accountants who allegedly failed to file returns or extensions, gave incorrect deposit instructions, or made inadvertent errors.<br /><br />The letters commonly emphasize prior compliance, good-faith efforts, ordinary business care and prudence, prompt corrective action, payment of tax once funds became available, and installment agreements. Some invoke first-time abatement, IRS administrative procedures, or the “more likely than not” standard when a timely extension was believed to have been filed. Accuracy-penalty protests often describe omitted income as an honest mistake, explain reliance on a preparer, or contest the underlying examination findings.<br /><br />Many requests cite Internal Revenue Manual provisions, tax regulations, and court cases, and refer to supporting evidence such as medical records, bank statements, receipts, police reports, tax transcripts, and correspondence. The document provides advocacy examples, not rulings on whether the IRS granted the requested relief.

Keywords

IRS penalty abatement

reasonable cause

late filing penalty

late payment penalty

payroll tax deposits

estimated tax underpayment

accuracy-related penalty

Appeals conference

first-time abatement

tax protest letters