SEE-3 - Specific Areas of Representation - Section 3.2

Request abatement of penalties and interest, applying reasonable cause, first-time abatement, and the limited grounds on which the IRS will abate interest.

Request abatement of failure-to-file and failure-to-pay penalties by establishing reasonable cause - circumstances beyond the taxpayer's control despite ordinary business care - or by using the administrative first-time abatement waiver for an otherwise compliant taxpayer. Recognise that interest is generally not abatable except where attributable to unreasonable IRS error or delay in performing a ministerial or managerial act.

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