I have a different answer....
As I really tried to tell you earlier, you need to be going through appeals here.
The form 5472 is not only available to be submitted with request for abatement (IF you've filed timely - with extensions - and have a clean compliance history)...
... but you also may request relief through the voluntary the penalty will be waived if you reference FAQ17 of the 2011 Voluntary Disclosure program (updated through 2013) See this: http://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-Disclosure-Program-Frequently-Asked-Questions-and-Answers
What they may have told you was that first time abatement doesn't apply to S-Corps (and there are a couple of other exceptions) but reasonable cause applies across the board.
But again, if you continue dealing with the the collectors on the front lines without either using appeals or the OVD reference, you'll keep getting conflicting information and going in circles.
See this from the IRS internal manual:
Criteria for Relief From Penalties
Generally, relief from penalties falls into four separate categories:
Correction of Service errorAPPEALS
may recommend the abatement or non-assertion of a penalty based on these four criteria as well as "hazards of litigation."
Also Don't limit your argument to reasonable cause ...
From: http://www.cpa2biz.com/Content/media/PRODUCER_CONTENT/Newsletters/Articles_2012/CPA/Nov/PenaltyAbatement.jspAppeals nonassertion or relief due to hazards of litigation.The IRS Office of Appeals can waive penalties
to settle a case based on “hazards of litigation,” which is the probability that the IRS determination will not be upheld in court. For example, an IRS Appeals officer may waive penalties in an appeals hearing to reach an agreement with the taxpayer. This is used primarily for accuracy-related penalties in Appeals proceedings involving audits.
Administrative waiver.The IRS may formally interpret or clarify a provision to provide administrative relief from a penalty it would otherwise assess. The IRS may address an administrative waiver in either a policy statement, news release, or other formal communication stating that the policy of the IRS is to provide relief from a penalty under specific conditions. For example, in 2012, the IRS provided relief for the failure-to-pay penalty for taxpayers with financial hardship (see IR-2012-31).
You really need to consider slowing this all down by going through appeals.
You keep dancing with the clerks on the front lines and you'll never get the benefit of the doubt.
Appeals with help you examine you options (reasonable cause,administrative waiver, financial hardship) after having a reasonable conversation with a manager, rather than continuing this disjointed game of mail and telephone tag with the clerks on the front lines.
And don't let them tell you that you have to have a levy or lien
or threat thereof ... once you get to them, they'll work with on any reasonable request such as your . I've done it for clientshttp://www.irs.gov/Individuals/Appeals...-Resolving-Tax-Disputes