Penalty Abatement After Denial: Proven IRS Appeal Strategies That Work
From: $159.00
Date: October 23rd,2026
Time: 2pm ET | 1pm CT | 12pm MT | 11am PT
Duration: 120 Minutes
Description:
IRS penalties can quickly turn a routine filing issue into a costly client problem. After an extension deadline, late filing, an unpaid balance, or an IRS notice, practitioners need a clear process for determining whether penalty relief is availableand how to document it effectively.
This practical CPE webinar provides a step-by-step guide to IRS penalty abatement, with a focused comparison of First-Time Abatement and reasonable-cause relief. Drawing on the IRS Internal Revenue Manual’s penalty guidance, the session explains how the IRS evaluates abatement requests, what evidence supports approval, and why many otherwise valid requests are denied.
Through sample request letters, IRS response letters, and real-world scenarios, you will learn how to build a stronger abatement file from the outset. The course also addresses what to do when the IRS says no: how to interpret the denial, strengthen the factual record, respond strategically, and evaluate available Appeals options.
By the end of the session, you will be better equipped to advise clients, prepare persuasive abatement requests, reduce avoidable penalty exposure, and pursue the appropriate relief path when initial requests are unsuccessful.
Topics Covered:
Overview of IRS penalties and the penalty-abatement framework.
First-Time Abatement (FTA): eligibility, compliance history, limitations, and common pitfalls.
Reasonable-cause penalty abatement and the ordinary business care and prudence standard.
Death, serious illness, or unavoidable absence as support for reasonable cause.
Fire, casualty, natural disaster, or other disturbance and the documentation required.
Reliance on erroneous advice from the IRS or a tax professional.
Reviewing and responding to IRS approval, partial-approval, and denial letters.
Strategies for strengthening a denied request with additional evidence and legal support.
Appeals options after denial, including administrative appeals and related procedural considerations.
Learning Objectives :
Distinguish between First-Time Abatement (FTA) and reasonable-cause penalty abatement, including when each relief option applies.
Identify the eligibility requirements, limitations, and documentation needed for FTA and penalty abatement requests.
Apply the IRS reasonable-cause standard, including ordinary business care and prudence, to real client fact patterns.
Evaluate sample penalty-abatement request letters and recognize the elements that make a submission persuasive.
Analyze actual IRS response letters to identify why abatement requests are approved, partially approved, or denied.
Develop effective responses to IRS denials, including supplemental documentation and revised relief requests.
Assess the Appeals options available after a denied penalty-abatement request and select the most appropriate next step.
Recognize common factual and documentation mistakes that weaken penalty-relief requests.
Credits and Other information:
Recommended CPE credit – 2.0
Recommended field of study – Taxes
Session Prerequisites and preparation: None
Session learning level: Basic
Location: Virtual/Online
Delivery method: Group Internet Based
Attendance Requirement: Yes
Session Duration: 120 minutes
Who Will Benefit:
CPA
Enrolled Agents (EAs)
Tax Professionals
Attorneys
Other Tax Preparers
Finance professionals
Financial planners
About Our Speaker :
Robert Nordlander, CPA, CFE
Robert Nordlander is a nationally recognized forensic accountant, tax-resolution practitioner, author, and speaker. He spent more than 20 years as a Special Agent with IRS Criminal Investigation, where he investigated complex federal tax, money-laundering, and white-collar crime cases in the United States and internationally.During his IRS-Criminal Investigation career, he worked on multi-million-dollar cases involving tax evasion, money laundering, and other financial crimes. He also served as a certified IRS instructor, developing and teaching forensic-accounting training in the United States and abroad.His practice focuses on forensic accounting, criminal tax matters, tax controversy and resolution, financial-crime litigation support, and expert-witness services for attorneys
