Webinar: Penalty Relief for Nonfilers: Automatic Exemption from Penalty, First Time Abate, and Reasonable Cause by ALFi

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Presenter

Matt Eddleman

Matt Eddleman brings more than two decades of professional experience in tax controversy, accounting, financial planning, and small business management to Frost Law's Tax Compliance team.

About

Program Field of Study: Taxes | Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, tax preparers, attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: While attending previous "Coming Out of the Dark" sessions build upon concepts covered in past courses, no preparation is needed for this course.
Prerequisite: None
IRS Program Number: JWRXB-T-00043-26-O

For many nonfilers, the tax is the smaller problem. The penalties and interest are what make the balance unmanageable. This session covers how the IRS computes the failure-to-file, failure-to-pay, and related additions on delinquent returns, and how to get them reduced or removed. It explains the IRS’s new Automatic Exemption from Penalty, how it differs from First Time Abate, and why neither reaches most multi-year nonfilers beyond the first delinquent year. The core of the session is the reasonable cause standard under §6651(a) and the regulations, and how to build a documented request that survives review. It closes with the procedural paths for requesting relief, and the penalties and interest that relief generally does not reach.

Agenda

Discuss the §6651 additions for a delinquent return, including how the failure-to-file and failure-to-pay penalties interact, the rate increase after notice of intent to levy, the minimum penalty, and the §6651(f) fraud exposure
Distinguish Automatic Exemption from Penalty from First Time Abate, including the tax years each covers, the timely-compliance test, the penalties each reaches, and whether the penalty is prevented or assessed and then removed
Determine which delinquent years of a multi-year nonfiler can qualify for FTA or AEP, and explain why the timely-filing requirement generally limits relief to the earliest delinquent year
Apply the reasonable cause standard (Treas. Reg. §301.6651-1(c), IRM 20.1.1.3.2, and United States v. Boyle) to common nonfiler fact patterns, and prepare a supported narrative
Identify the right procedure (a call, a written statement or Form 843, Appeals, or judicial review), and what relief does not resolve, including §6654 and interest not tied to an abated penalty