Responding to Common IRS Notices: 90-Day Letters, First-Time Penalty Abatement, and Reasonable Cause Relief

Note: CLE credit is not offered on this program

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

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Conducted on Tuesday, March 3, 2020

Recorded event now available

or call 1-800-926-7926
Course Materials

This course will explain the many types of notices issued by the IRS, including how to appropriately respond to each, how to properly request abatement of penalties charged, and current IRS responses to abatement requests.


Every IRS notice received contains potential penalties and a required response date. Responding appropriately and effectively can provide relief from penalties and often undeserved additional tax liability for clients. One of the most common notices, the CP 2000, is sent to collect underreported income. This is often the result of a mismatch of information, the difference between what was reported to the IRS and what was included on a taxpayer's return.

More alarming is CP 3219A, a Statutory Notice of Deficiency, better known as a 90-day letter or a ticket to tax court. Responding timely and adequately is critical. Or, better yet, take steps to avoid this notice altogether.

Taxpayers have reasonable defenses against penalties charged with these notices. Some forgiveness is automatic. For example, taxpayers can take advantage of first time penalty abatement if they qualify and request appropriately. In other cases, there may be reasonable cause, reliance on a professional, or facts and circumstances that allow penalty relief. Knowing how to respond to each type of IRS notice correctly and the proper steps to take for penalty abatement is critical for practicing tax professionals.

Listen as our panel of seasoned experts explains the different types of IRS notices, the appropriate responses to each, and how to mitigate penalties charged to taxpayers.



  1. IRS notices: an overview
  2. Types of notices
    1. CP 2000
    2. CP 3219A
    3. Other notices
  3. Requesting penalty abatement
  4. IRS responses to abatement requests
  5. CPAs, Tax attorneys, and Kovel arrangements


The panel will review these and other critical issues:

  • How to appropriately respond to common IRS notices
  • How to request first time penalty abatement
  • What are reasonable cause exceptions to specific penalties
  • How to respond to a 90-day letter
  • IRS responses to penalty abatement requests


Capdevielle, Cliff
Cliff Capdevielle

Managing Attorney

Mr. Capdevielle has been developing sophisticated tax planning strategies and resolving tax disputes for clients more...  |  Read More

Smeltzer, Joshua
Joshua D. Smeltzer

Brown Fox

Mr. Smeltzer is a tax attorney with over 15 years of experience representing individuals, corporations, and formerly...  |  Read More

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