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FBAR Penalties, Reasonable Cause
Whether a failure to file or failure to pay is due to reasonable cause is based on a consideration of the facts and circumstances. Each case is very different.
IRS reasonable cause relief is generally granted by the IRS when you demonstrate that you exercised ordinary business care and prudence in meeting your tax obligations but nevertheless failed to meet them.
Documentation is a key criteria.
In determining whether you exercised ordinary business care and prudence, the IRS will consider all available information, including but not limited to :
1. The reasons given for not meeting your tax obligations;
2.Your compliance history;
3. The length of time between your failure to meet your tax obligations and your 4.Subsequent compliance; and
5.Circumstances beyond your control.
IRS reasonable cause may be established if you show that you were not aware of specific obligations to file returns or pay taxes, depending on the facts and circumstances of your case.
Among other of facts and circumstances that will be considered by the IRS are:
1. Your education;
2.Whether you have previously been subject to the tax;
3. Whether you have been penalized before;
4.Whether there were recent changes in the tax forms or law that you could not reasonably be expected to know; and
5. The level of complexity of a tax or compliance issue.
You may have reasonable cause for noncompliance due to ignorance of the law if a reasonable and good faith effort was made to comply with the law or you were unaware of the requirement and could not reasonably be expected to know of the requirement.
FBAR Penalties, IRS Tax Help, Owe Back Taxes, Settle, Former IRS, Tax Attorneys, Lawyers, FBAR Experts
