Does First Time Abatement eligibility change if paying off an earlier year balance?


#1

Client owes failure to pay penalties for 2011 thru 2014, and 2009. Also owes accuracy related penalty for 2008.

Currently the FTA is available for 2009. If the client pays off the 2008 and 2009 amounts, does that make the 2011 automatically eligible for FTA?


#2

No. If you read the FTA IRM, regardless of payment of penalties, the Intent was " did tp have any penalties in the 3 preceding years?". You can always try!


#3

Marc, thanks. I may try, but I thought someone else might have had the experience. it would be the difference from $495 to >$6,000.