I am responding to a notice that my client failed to file a Form 8865 with respect to a foreign partnership and would like to apply for penalty abatement based on reasonable cause. I understand from the IRM that the first time abatement program is not available for this penalty.
Is there a Form for the reasonable cause abatement or should I just draft it in letter format?
Also, I am not finding any search function on the TRN website… am I missing this? I feel like this question is addressed in a podcast or training I listened to but can’t seem to locate it…
Nora, yes I am sorry but I am just checking Forum posts now. You use the 843 and attach a statement explaining why the taxpayer should receive reasonable cause abatement. I would point out a good filing and payment history if they have it.