THE TAXPAYER IS IN RECEIPT OF LETTER NUMBER 2697C IN REGARDS TO THE TAX PERIOD ENDED DECEMBER 31, 2020, IN WHICH THEIR FORM 990PF WAS NOT ACCEPTED BY THE INTERNAL REVENUE SERVICE, AS IT WAS NOT ELECTRONICALLY FILED. IN THE FOLLOWING PARAGRAPH THE TAXPAYER WILL DEMONSTRATE ITS' CASE FOR AN ABATEMENT OF THE PENALTIES STATEMENTS OF FACTS AND CIRCUMSTANCES LEADING TO NONCOMPLIANCE THE TAXPAYER HAD THEIR FORM 990PF COMPLETED BY A DIFFERENT ACCOUNTANT. THE ACCOUNTANT WAS EITHER UNAWARE OF THE TAXPAYER FIRST ACT REQUIRING FORM 990PFS TO NOW BE EFILED OR SIMPLY MADE A CLERICAL ERROR AND HAD IT PAPER FILED. ONCE THE TAXPAYER BECAME AWARE OF THE ISSUE, THEY RETAINED THIS FIRM TO HAVE THEIR FORM 990PF FOR THE TAX PERIOD ENDED DECEMBER 31, 2020 ELECTRONICALLY FILED. DEMONSTRATING REASONABLE CAUSE THE TAXPAYER TAKES ITS' FILING OBLIGATIONS SERIOUSLY AND HAS ALWAYS FILED ALL TAX FILINGS ON TIME, INCLUDING THE RETURN ENDING DECEMBER 31, 2020.IRS REGULATION 301.6724-1(A) STATES THAT THE PENALTY FOR A FAILURE RELATING TO A REPORTING REQUIREMENT IS WAIVED IF THE FAILURE IS DUE TO REASONABLE CAUSE. REASONABLE CAUSE MAY BE DEMONSTRATED IF THE FILER ESTABLISHES THAT THERE ARE SIGNIFICANT MITIGATING FACTORS WITH RESPECT TO THE FAILURE AND THAT THE FILER ACTED IN A RESPONSIBLE MANNER BY EXERCISING REASONABLE CARE, WHICH IS THAT STANDARD OF CARE THAT A REASONABLY PRUDENT PERSON WOULD USE, AND THAT THE FILER UNDERTOOK SIGNIFICANT STEPS TO AVOID OR MITIGATE THE FAILURE. AS PROVIDED UNDER TREASURY REGULATION SECTION 301.6724-1(A), SIGNIFICANT MITIGATING FACTORS INCLUDE ALL PRIOR FILINGS BEING FILED TIMELY AND NO PREVIOUSLY ASSESSED PENALTIES AGAINST THE TAXPAYER FOR NON-COMPLIANCE ISSUES RELATED TO REQUIRED INFORMATIONAL FORM 990 FILING REQUIREMENTS. REQUEST FOR ABATEMENTNO PENALTY HAS BEEN ASSESSED IN THE ABOVE NOTICE. ADDITIONALLY THE TAXPAYER, HAVING FILED THEIR FORM 990PF TIMELY, DID NOT REALIZE THAT THERE WAS AN ISSUE UNTIL AFTER THE APRIL 15 DEADLINE. THE ABSENCE OF "WILLFUL NEGLECT" HAS BEEN DEEMED BY THE IRS TO BE ONE FACTOR THAT MAY INDICATE THE EXISTENCE OF REASONABLE CAUSE. THE TAXPAYER HAS NOT SHOWN WILLFUL NEGLECT WITH RESPECT TO ITS FILING OBLIGATIONS AND BELIEVES THEY HAVE DEMONSTRATED THIS WITH THE STATEMENTS AND EVIDENCE IN THIS REQUEST.THE TAXPAYER BELIEVES THAT IT FALLS WITHIN THE REASONABLE CAUSE ABATEMENT PROVISIONS OF THE CODE BY HAVING ESTABLISHED SIGNIFICANT MITIGATING FACTORS WITH RESPECT TO THE FAILURE, AND BY ESTABLISHING THAT THEY ACTED RESPONSIBLY TO CORRECT THE FAILURE, ONCE DISCOVERED. THE TAXPAYER HAS ALWAYS HAD EVERY INTENTION OF BEING IN COMPLIANCE WITH ALL OF ITS FILING REQUIREMENTS.THE TAXPAYER RESPECTFULLY REQUESTS THAT SHOULD THE IRS ISSUE PENALTIES IN THE FUTURE THAT THEY ABATE ALL PENALTIES ASSESSED FOR THE LATE FILING OF FORM 990PF FOR THE YEAR ENDED DECEMBER 31, 2020 AND APPRECIATES YOUR CONSIDERATIONS OF OUR REQUEST.UNDER PENALTIES OF PERJURY, THE TAXPAYER HEREBY DECLARES THAT THE STATEMENTS CONTAINED HEREIN, TO THE BEST OF OUR KNOWLEDGE AND BELIEF, ARE TRUE, CORRECT, AND COMPLETE.
Application Information
Accepts Unsolicited ProposalsNo — Preselected Only