>>> FORMER IRS ATTORNEY --- PATRICK T. SHEEHAN >>> 

>>> SERVICES: REQUEST FOR PENALTY ABATEMENT BASED ON REASONABLE CAUSE >>>

>>> IRS COLLECTION EFFORTS

>>> COLLECTION - INDIVIDUAL

>>> COLLECTION - BUSINESS

>>> OFFER IN COMPROMISE

>>> PAY OVER TIME/INSTALLMENT AGREEMENT

>>> INNOCENT SPOUSE RELIEF

>>> REQUEST FOR PENALTY ABATEMENT BASED UPON REASONABLE CAUSE

>>> DEEMED UNCOLLECTIBLE

>>> TRUST FUND RECOVERY PENALTY

>>> AUDITS AND AUDIT RECONSIDERATION

>>> STATUTE OF LIMITATION

>>> BANKRUPTCY

>>> JURISDICTION OF FEDERAL COURTS / TAX LITIGATION

>>> IRS NOTICES

PENALTIES AND RELATED INTEREST often constitute a substantial portion of the total unpaid liability. However, penalties and related interest are subject to abatement. In instances where a taxpayer has filed his or her tax return late, or is unable to pay his or her tax liability, but has a legitimate reason for doing so, he or she may file a Request for Penalty Abatement Based Upon Reasonable Cause.

A Request for Penalty Abatement Based Upon Reasonable Cause is a legal argument submitted to the IRS discussing the facts and circumstances resulting in the late-filed tax return or unpaid tax liability and forms the legal basis for seeking abatement of the penalties. In evaluating a Request for Penalty abatement, the IRS considers the specific facts and circumstances of each case. The IRS may grant penalty abatement when the taxpayer exercises ordinary business care and prudence in determining his or her tax obligation but is unable to comply with those obligations because of extenuating facts or circumstances.

The extenuating facts or circumstances form the basis of the Request for Penalty Abatement. The IRS has not provided a list of specifically enumerated facts and circumstances constituting reasonable cause. However, examples of extenuating circumstances considered by the IRS include a death in the family, serious illness, addiction, and natural disasters. We stress that these extenuating circumstances are only a sampling of situations that may constitute reasonable cause, thereby making a taxpayer eligible for penalty abatement.

Patrick T. Sheehan & Associates, Attorneys at Law, P.C. has been extremely successful in obtaining abatement of penalties and related interest in many cases. If you are interested in learning more about penalty relief, please call us.

We can help. Call us before the IRS calls you! ®


Patrick T. Sheehan & Associates, Attorneys At Law, P.C.  | DISCLAIMER | 1-877-447-7529  | CONTACT