Segal, Cohen & Landis, P.C.
Challenge IRS Form 3520 Penalties — Attorney-Led Defense
IRS tax attorneys — Beverly Hills, CA. National representation.
For unreported foreign gifts, IRC §6039F generally provides a penalty of 5% per month, up to 25% of the gift. Foreign trust reporting follows different rules under IRC §6677: initial penalties generally equal the greater of $10,000 or 35% of an unreported transfer or distribution; certain ownership-reporting failures use 5% of the relevant trust assets. Additional penalties and statutory limits may apply. The maximum penalty is not an inevitable outcome in every case.
We review the filing obligation, transaction type, notice, deadlines and supporting records before recommending a response. Reasonable-cause relief may be available, but ignorance of the requirement or reliance on a preparer does not automatically qualify. We assess the evidence and available administrative or court procedures; no reduction or particular result is guaranteed.
How We Help
Our Approach to Form 3520 Penalty Defense Attorney
Reasonable Cause Abatement Requests
We prepare a supported reasonable-cause request when the facts justify it. Reliance on advice must be evaluated in context; relief is not automatic.
IRS Appeals
We review the notice and available appeal or refund procedures, including deadlines and any payment requirements. The appropriate forum depends on the assessment and procedural history.
Delinquent Form 3520 Filing
Simultaneously with penalty abatement, we ensure the underlying Form 3520 is filed correctly and completely.
How It Works
The Resolution Process
Penalty Analysis
We review the IRS assessment, identify all applicable penalty periods, and calculate whether the IRS has correctly applied the penalty formula.
Reasonable Cause Development
We interview the taxpayer, gather evidence of reasonable cause, and identify applicable legal arguments and precedent supporting abatement.
Abatement Request Submission
We review the filing obligation, transaction type, notice, deadlines and supporting records before recommending a response. Reasonable-cause relief may be available, but ignorance of the requirement or reliance on a preparer does not automatically qualify. We assess the evidence and available administrative or court procedures; no reduction or particular result is guaranteed.
Appeals or Litigation
If initial abatement is denied, we escalate to IRS Appeals or evaluate litigation in federal district court based on the amount at issue.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
Can Form 3520 penalties be waived?+
We prepare a supported reasonable-cause request when the facts justify it. Reliance on advice must be evaluated in context; relief is not automatic.
What is reasonable cause for a Form 3520 penalty?+
We review the filing obligation, transaction type, notice, deadlines and supporting records before recommending a response. Reasonable-cause relief may be available, but ignorance of the requirement or reliance on a preparer does not automatically qualify. We assess the evidence and available administrative or court procedures; no reduction or particular result is guaranteed.
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Further reading
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
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