Failure to File Form 8865

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    Nora Muller

    Hi TRN,

    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…

    Thanks for any guidance on this.


    Nora Muller

    I am responding to my own question – the Form seems to be the 843!

    Eric Green

    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.

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