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Jonathan Tierney
Jonathan Tierney, Certified Public Accountant (CPA)
Category: Tax
Satisfied Customers: 322
Experience:  Tax Accountant at Praxair, Inc.
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What it is a valid reasonable cause to dispute penalty under

Customer Question

what it is a valid reasonable cause to dispute penalty under code 6699
Submitted: 2 years ago.
Category: Tax
Expert:  Jonathan Tierney replied 2 years ago.

Hi, my name is ***** ***** my goal here is to provide you with the most complete and accurate answer possible.

The easiest way to get out of a late filing penalty is through first time penalty abatement, which is not actually a reasonable cause under IRC 6699 or even in the IRC at all. It is an administrative practice the IRS has implemented to reward otherwise responsible taxpayers. You can read about the FTA (first time abatement) here: as well as and IRS documents regarding whether a FTA should be granted.

Reasonable cause is generally difficult to demonstrate. You need to show that the corporation took the necessary steps to comply with it tax filing obligations but unforeseen circumstances prevented it from doing so. Events such as the loss or destruction of corporate records, the death or disability of a tax return preparer or other key person in ensuring the return get files should qualify as reasonable cause. A power outage preventing the use of computers needed to access information or to prepare return could be a reasonable cause. A major weather event that prevents the mail from being picked up and being timely postmarked could also qualify. One final reason would be the corporation trusted a certain accountant or employee with the responsibility of taking care of the return, but they were not diligent in completing their duties, unknown to other in the corporation.

I hope this answers your question. Please let me know if I can clarify anything or answer any additional questions. Jonathan