Navigating Complex IRS Penalty Abatement Procedures for Failure-to-File, Failure-to-Pay, and Accuracy Related Penalties

Mastering Procedural and Practical Ways to Obtain Penalty Abatement; Mitigating Harsh IRS Penalties

Recording of a 110-minute CPE webinar with Q&A

Conducted on Wednesday, May 3, 2017
Recorded event now available

This webinar will provide tax professionals with a comprehensive and practical guide to navigating the procedural and practical ways to obtain a penalty abatement. The panel will cover domestic information abatement requests, and will offer useful tools for compiling and submitting the appeal correspondence and documentation.


The IRS assesses many types of penalties against taxpayers: late-filing penalties, late-payment penalties, estimated tax penalties, accuracy-related penalties, and the list goes on. Tax practitioners face these tax penalties on an almost a daily basis, and this webinar will provide procedural and practical ways to obtain a penalty abatement.

The IRS employs strict standards for determining whether a taxpayer qualifies for an abatement of penalties for failure to file required tax returns. TIGTA issued a report indicating that IRS controls over penalties were deficient, leading to incorrect abatement in a large percentage of tested cases. As a result, the IRS increased scrutiny over penalty abatement requests.

The Service has several appeal tracks for denial of abatement requests. Critical to navigating the appeals process is understanding what documentation is required based on the type of appeal and the basis for the taxpayer’s claim. Domestic abatement appeals require a significant amount of substantiation, which can often be difficult to obtain.

Listen as our experienced panel of advisers provides a thorough guide to navigating procedural and practical ways to obtain a penalty abatement.


  1. Failure-to-file and failure-to-pay penalties (Sec. 6651)
    1. Know how and when to attach a penalty non-assertion request to a late-filed return
    2. Learn to effectively establish an installment agreement
    3. Must learn how to effectively use “Office of Appeals”
  2. Estimated tax penalty (Sec. 6655)
    1. Must learn different methods of calculating penalties
    2. Effectively use the safe harbor rules
  3. Accuracy-related penalty (Sec. 6662)
    1. Determining certain tax authority standards (e.g., the “more likely than not” standard or “substantial authority” standard)
    2. Heavily substantiate a client’s reasonable-cause defense


The panel will discuss these and other important topics:

  • Penalty abatement qualifying requirements
  • Avoiding notice stream by using a penalty non-assertion request to a late-filed return.
  • Establishing an installment agreement and adhering to its terms to avoid penalties
  • Effectively using very subjective reasonable cause criteria
  • Utilizing “Office of Appeals” effectively
  • Methods of calculating penalties
  • Which taxpayers can take advantage of the first time abatement program?

Learning Objectives

After completing this course, you will be able to:

  • Discern the appeals process and documentation requirements for various types of IRS penalty appeals
  • Decide whether clients have sufficient grounds to appeal tax penalties for failure-to-file, failure-to-pay and accuracy-related penalties
  • Identify very subjective reasonable cause criteria
  • Recognize benefits of using “Office of Appeals” effectively


Joel N. Crouch, Managing Partner
Meadows Collier Reed Cousins Crouch & Ungerman, Dallas

Mr. Crouch specializ​es in civil and criminal tax controversies ​involv​ing sophisticated and complex legal and tax issues, both domestic and international.​ He has extensive experience in resolving tax matters at all stages of a tax dispute including IRS examinations, administrative appeals, and litigation in the U.S. Tax Court, the U.S. Court of Federal Claims and U.S. District Courts​, and before the United States Supreme Court. He is a frequent speaker on both substantive and procedural tax issues for both legal and accounting professionals.

Benjamin J. Peeler, J.D., CPA, LL.M., Partner
Eide Bailly, Utah

Mr. Peeler leads his firm's IRS Practices & Procedures team as a federal tax, controversy and procedure specialist. He works with clients in the controversy areas relating to income tax, estate and gift tax, property tax, employment tax and other various tax matters. He represents clients before the IRS in examination, appeals, collection, penalty abatement, audit reconsideration, interest abatement and interest netting. Previously, he worked as an attorney for the IRS Office of Chief Counsel, and also, led and instructed groups of attorneys, revenue agents and revenue officers through various procedures.

Judi Smith
The Law Office of Judi Smith, Peoria, Ariz.

Ms. Smith is in private practice. Previously, she served as the In-House General Counsel and Director of Strategic Services for a multinational corporation where she was responsible for domestic and international tax compliance. Prior to leaving, she successfully defended an IRS employment tax (941) audit which concluded with the IRS having no issues. She is authorized to practice before the IRS in all states and territories of the United States. She represents clients with tax issues residing in many countries including Russia, Sweden, India, and China (Hong Kong). She is admitted to practice in the United States Tax Court, the United States Court of Appeals for the Seventh Circuit, the United States District Court for the Northern District of Illinois and the Supreme Court of Illinois.

EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


Recorded Event

Includes full event recording plus handouts.

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $247.00

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Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

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Program Materials

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EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

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Customer Reviews

Provided a lot of information. Examples made it easier to put in everyday perspective.

Therese Au

Forsythe Technology

Real life examples that we could relate to.  Keep up the great work.

Brett Terrebonne


The program had excellent presenters that were extremely knowledgeable.

Lisa R. Volland

Legacy Professionals

It was an excellent program!!

Marni Odermann


I thought that the speakers were very knowledgeable and their presentation materials will be good reference guides.

Claudia Del Castillo, CPA

Sol Schwartz & Associates

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