What options are available if the IRS denies appeals for waiving missing form fee?
In June 2019, IRS sends Mr. X a letter with a fine of $7,200 for the missing 3 forms (each form cost maximum $2,400 = maximum 12 months * $200 late fee/month) and interest charges to be accrued. Mr. X calls the IRS and complains that the business just paid off >$50k and is now slapped with ~$10k in fees and fines! The representative waives the fees for two of the three missing forms due to First Time Penalty Abatement but says the third needs written explanation. Mr. X sends in the explanation letter, which is rejected, and Mr. X appeals, and in 2021 the IRS appeals office reaches out to Mr. X that there may be a call to help with remediation in an informal manner. Mr. X has the call coming up shortly and has never gone through this process and plans to tell them that it's not fair for the IRS to punish Mr. X has it was Mr. X who caught the issue in an informal self-audit and followed up to remedy the issue even though it did not fit the 30-day window and has never made that mistake again.