Not a payroll tax issue at all. Late-filed return penalty - but the return was filed late because the tax matters partner was incapacitated, his wife was fighting cancer, and the son running the business was taking care of them both and as a result doing almost no business. We sent in penalty abatement request that was rejected only because my POA had been signed by the TMP, who had died by the time the IRS read the letter, so the POA was no longer valid.