We respectfully request that the Foundation's quarterly estimated tax payments be treated as timely and request that no underpayment penalties be assessed because the payment delay was due to reasonable cause. Treasury Regulations SEC. 301.6651-1(c)(1) defines reasonable cause by asking whether the taxpayer exercised ordinary business care and prudence. The Foundation exercised care and prudence in seeking a reputable firm knowledgeable about exempt organizations to submit a payment in a timely fashion for Form 990-PF. Quarterly estimates for the taxable year ending December 31, 2024 990-PF were underpaid due to administrative error. The Foundation's administrator incorrectly used an erroneous incorporation date in its system, which caused it to calculate two quarterly estimated tax payments instead of the required four. Unbeknownst to the Foundation, this error resulted in an underpayment of the quarterly estimates. Once the error was discovered, the Foundation's administrator corrected the incorporation date in its system. According to the standards set forth in Rev. Proc. 92-85, we believe the Foundation's actions were reasonable and in good faith. The underpayment of quarterly estimates was not in any way due to an intentional disregard of IRS rules, but rather a clerical error. We respectfully request that no penalties be assessed in connection with underpayment penalties for estimated taxes.
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