Complex IRS Penalty Abatement Procedures for Failure-to-File, Failure-to-Pay, and Accuracy-Related Penalties

About the Course

Introduction

This CPE course will provide tax professionals with a comprehensive and practical guide to navigating the procedural and efficient ways to obtain a penalty abatement. The panel will cover domestic and foreign information abatement requests and offer valuable tools for compiling and submitting the appeal correspondence and documentation.

Description

The IRS assesses many types of penalties against taxpayers: late-filing penalties, late-payment penalties, estimated tax penalties (Secs. 6654 and 6655), accuracy-related penalties, and so on. Tax practitioners face these tax penalties almost daily, and this webinar will provide procedural and practical ways to obtain a penalty abatement.

The IRS employs strict standards for determining whether a taxpayer qualifies for a reduction in penalties for failure to file required tax returns. TIGTA issued a report indicating that IRS controls over penalties were deficient, leading to incorrect abatement in many tested cases. As a result, the IRS increased scrutiny over penalty abatement requests.

The Service has several appeal tracks for denial of abatement requests. Understanding the required documentation, which depends on the type of appeal and the basis for the taxpayer's claim, is critical to navigating the appeals process. Abatement appeals require significant substantiation, which can often be challenging to obtain.

Listen as our experienced panel of advisers provides a thorough guide to navigating procedural and practical ways to obtain a penalty abatement.

Credit Information

BARBRI is a NASBA CPE sponsor and this 60-minute webinar is accredited for 1.0 CPE credits.

Date + Time

event
Tuesday, December 1, 2026
schedule
1:00 p.m. ET./10:00 a.m. PT

I. Failure-to-file and failure-to-pay penalties (Sec. 6651)

A. Know how and when to attach a penalty non-assertion request to a late-filed return

B. Establish an installment agreement

II. Estimated tax penalty (Sec. 6655)

III. Accuracy-related penalty (Sec. 6662)

A. Determining specific tax authority standards (e.g., the "more likely than not" standard or "substantial authority" standard)

B. Fully substantiating a client's reasonable cause defense

IV. Best use of the Independent Office of Appeals

V. Exploiting the IRS' failure to follow 6751(b)—the Graev defense

VI. Using CDP hearings to abate penalties

VII. Foreign informational return penalties (for example, Forms 5471, 5472, 3520, and 3520-A)

A. Avoiding automatic assessments through the streamlined process

B. Reasonable cause standard for foreign information reporting forms

C. Litigation overview

The panel will discuss these and other relevant topics:

Penalty abatement qualifying requirements
Penalty non-assertion request to a late-filed return
Using very subjective reasonable cause criteria
Utilizing the Independent Office of Appeals
Methods of calculating penalties
Qualifying for the first-time abatement program

Learning Objectives

After completing this course, you will be able to:

Recognize the penalty abatement qualifying requirements
Identify how penalties are calculated
Know how and when to assert reasonable cause or to establish an installment agreement
Understand foreign information reporting penalties
Discern when to use CDP hearings to abate penalties
Differentiate estimated tax penalties from other tax penalties

Field of Study:
Level of Knowledge:
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite:
Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Specific knowledge and understanding of Section 6651, 6655 and 6662 penalties imposed by the IRS.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

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