Segal, Cohen & Landis, P.C.
Reduce Your IRS Debt by Eliminating Penalties
IRS tax attorneys — Beverly Hills, CA. National representation.
IRS penalties are not fixed — they can be challenged, reduced, and eliminated. The IRS assesses hundreds of different types of penalties, but the most common for individuals and businesses are the failure-to-file penalty (5% per month up to 25%), failure-to-pay penalty (0.5% per month up to 25%), and accuracy-related penalty (20% of underpayment). When combined with compounding interest, penalties can add 50% or more to the underlying tax debt. Penalty abatement is often the fastest and most underutilized way to reduce an IRS balance. At Segal, Cohen & Landis, we pursue every available abatement avenue — First Time Abatement, reasonable cause arguments, and statutory exceptions — to reduce what you owe.
How We Help
Our Approach to IRS Penalty Abatement Attorney
First Time Abatement (FTA)
The IRS's First Time Abatement program allows qualifying taxpayers to remove failure-to-file, failure-to-pay, and failure-to-deposit penalties for the first year of noncompliance — without having to demonstrate a reason. Eligibility requires a clean compliance history for the three preceding years. Many taxpayers who qualify never request it. We always check FTA eligibility first.
Reasonable Cause Abatement
Beyond FTA, the IRS will abate penalties when the taxpayer had a reasonable cause for noncompliance and acted in good faith. Recognized causes include serious illness, death in the family, natural disasters, reliance on incorrect advice from the IRS or a tax professional, and inability to obtain necessary records. We build the strongest possible reasonable cause argument backed by documentation.
Statutory and Administrative Exceptions
Certain penalty types have statutory exceptions — circumstances where the IRS cannot legally assess the penalty. We identify whether any statutory defense applies to your situation.
Penalty Abatement in OIC and Installment Contexts
Penalty abatement can be pursued independently or as part of a broader resolution strategy. Reducing the balance through abatement can bring the debt within OIC or streamlined installment agreement thresholds, opening resolution options that otherwise wouldn't be available.
How It Works
The Resolution Process
Penalty Analysis
We pull your IRS transcripts and identify every penalty assessed — type, amount, and year. We evaluate FTA eligibility, reasonable cause arguments, and statutory defenses.
Abatement Request
We prepare a written abatement request, whether via Form 843 or correspondence. Reasonable cause requests include a factual narrative and supporting documentation.
IRS Review
The IRS reviews the request. We respond to any follow-up requests and track the status.
Appeal if Denied
If the abatement is denied, we appeal within the IRS administrative process. Appeals often reverse or partially grant initial denials.
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
How much can penalty abatement save?+
Penalty savings vary widely. Failure-to-file and failure-to-pay penalties can total 47.5% of the underlying tax if both apply. Accuracy penalties add another 20%. On a $100,000 tax balance, penalty abatement alone could eliminate $40,000–$70,000 in assessments.
Do I have to pay the tax before I can get penalties abated?+
No. Penalty abatement can be requested regardless of whether the underlying tax has been paid. However, the failure-to-pay penalty continues to accrue on unpaid balances — so resolving the underlying debt and pursuing abatement simultaneously is often the most efficient strategy.
Can the IRS deny First Time Abatement?+
The IRS can deny FTA if you don't meet the compliance history requirements (previous three years of compliance) or if the penalty type doesn't qualify. We verify eligibility before requesting FTA.
What counts as 'reasonable cause' for penalty abatement?+
The IRS recognizes: serious illness or incapacitation, death of a family member, natural disaster, advice from IRS or a tax professional that turned out to be incorrect, inability to obtain records needed to file, and certain other circumstances. The cause must directly explain the failure to comply.
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
Free Confidential Consultation