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FIRST TIME ABATEMENT


BLACK BART

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Does IRS' First-time Penalty Abatement cover underpayment of estimated tax penalty?  Seems to me like failure to pay would be the only possibility among the three f's: failure to file-pay-deposit.

Since my guy actually didn't even make any estimates at all and owes about 15K, they probably wouldn't view him sympathetically, but, on the other hand, he's got the required clean tax track record.  Is it agent's discretion or what?

 

P.S. Seen any good movies lately? I swear I'm gonna cancel Direct if they switch one more channel to PPV.:D

 

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3 hours ago, BLACK BART said:

Does IRS' First-time Penalty Abatement cover underpayment of estimated tax penalty?  Seems to me like failure to pay would be the only possibility among the three f's: failure to file-pay-deposit.

No, it doesn't. FTA doesn't give the ability to request removal of the estimated penalty or accuracy-related penalties. The 2210 underpayment penalty is sec 6654, and the IRM here shows only those penalties that can be abated under the FTA:

Quote

20.1.1.3.3.2.1 (10-19-2020)

First Time Abate (FTA)

1. IRS provides administrative relief from the following penalties if the qualifying criteria contained in this subsection are met:

  • a. Failure to file (FTF) penalty under IRC 6651(a)(1), IRC 6698(a)(1), or IRC 6699(a)(1),
  • b. Failure to pay (FTP) penalty under IRC 6651(a)(2) and/or IRC 6651(a)(3), and
  • c. Failure to deposit (FTD) penalty under IRC 6656.
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