Enrolled agent Hugo Vantongeren represents Priscilla Okonkwo, who owes interest on a 2022 deficiency. The delay arose entirely because an IRS examiner misplaced her case file for several months after she had fully responded, performing no work during that managerial lapse. Priscilla did nothing to cause the delay. She asks whether the interest for that period can be removed. Under the IRS abatement procedures, what is the BEST basis for Hugo to assert?
- AReasonable cause for the late payment of the deficiency, since Priscilla acted with ordinary business care throughout and should not bear interest she could not avoid.
- BAbatement of interest attributable to the period of unreasonable IRS delay in performing a managerial act, where no significant part of the delay is attributable to the taxpayer. Correct
- CFirst-time abatement of the interest, because Priscilla has a clean compliance history and the administrative waiver extends to interest charged during a period of IRS inaction.
- DAbatement of the entire interest balance on the deficiency, because any unreasonable IRS managerial delay voids all interest that accrued on that liability from the original due date.
Why A is wrong: Reasonable cause is the right frame for many penalties, so it feels natural here, but reasonable cause does not abate interest; interest abatement turns on IRS error or delay, not on the taxpayer's own diligence.
Why B is correct: Interest may be abated when it is attributable to unreasonable error or delay by the IRS in performing a managerial or ministerial act and no significant aspect of the delay is the taxpayer's fault; a misplaced file causing months of inaction fits, so this is the proper basis for the period of delay.
Why C is wrong: Stretching the clean-history waiver to interest is tempting, but first-time abatement covers only specified penalties and never interest, so a clean record does not support removing the interest on this ground.
Why D is wrong: Wiping out all the interest sounds like the natural remedy for an IRS blunder, but abatement reaches only the interest attributable to the period of the unreasonable delay, not interest that accrued before or apart from the lapse.