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H&A Successful in Obtaining $103,000 Penalty Abatement


By Joe Nagel, Esq., LLM, CPA

H&A has again successfully helped obtain abatement of an IRS penalty.  In this case, the estate failed to file a return due to accountant error.  The CPA who caught the mistake filed an estate tax return for the client within a reasonable time after identification of the error.  Despite there being obvious reasonable cause for the late filing, the IRS agent obstinately assessed a late filing penalty of over $103,000.  H&A consulted on the case and drafted the protest letter which was accepted by the IRS Appeals Officer.

We cannot guaranty abatement of penalties, and success or failure of any request for abatement of penalties will be based on the facts and circumstances of the individual case.  If you need help dealing with the IRS, please do not hesitate to contact us at (404) 255-7400 or info@hoffmanestatelaw.com.


  • Joe Nagel

    Joe joined Hoffman & Associates in 2000 and became a partner in 2007. He is licensed to practice law in Georgia, Florida, North Carolina, and Ohio and is also a Certified Public Accountant. Joe serves clients in the areas of estate planning, corporate law, employment law, mergers and acquisitions, succession planning, income and estate tax planning, and tax controversy.

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