Penalty Abatement

The firm has successfully represented individuals and companies seeking relief from civil tax penalties. If a client meets the criteria for penalty abatement, a penalty abatement request can be an effective way to substantially reduce a client’s balance due to governmental taxing agencies and provide a more manageable work out. A sampling of our lawyers’ representative work includes:

• Clients who have failed to file a return on time or failed to pay the tax by the specified due date and are seeking abatement of penalties based upon reasonable cause.
• Clients seeking to contest penalties for failure to file international information returns such as Form 114, Report of Foreign Bank and Financial Account (FBAR) or Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporation.
• Clients who are facing the imposition of the trust fund recovery penalty, where the IRS seeks to assess a penalty against an individual or individuals who were responsible for paying the trust fund taxes, but who willfully did not do so.