Updated November 2026 · VG CPA PC advisors
First-time abatement
First-time abatement removes failure-to-file, failure-to-pay and failure-to-deposit penalties for one period if you had no significant penalties in the prior three years, have filed all required returns, and have paid or arranged to pay the tax. Estimated tax penalties do not count against you and are not covered.
It is an administrative waiver, so no explanation is needed. It can be requested by phone for smaller amounts or in writing, including on Form 843. It is often best used on the year with the largest penalty.
Reasonable cause
Reasonable cause relief applies when you exercised ordinary business care and prudence but still could not comply. Accepted reasons include serious illness or death in the family, natural disasters, fire, inability to obtain records, and reliance on erroneous written advice from the IRS or substantive advice from a professional.
The explanation must cover the whole period of noncompliance and show you acted promptly once the obstacle ended. Supporting documents, such as medical records or insurance claims, make the request far stronger.
What does not work
Under the Supreme Court's Boyle decision, relying on an accountant or attorney to file a return on time is not reasonable cause, because meeting a filing deadline is the taxpayer's own duty. Lack of funds alone is generally not reasonable cause for failure to pay, unless you show you used ordinary care and would have suffered undue hardship.
If the IRS denies the request, you can appeal. Penalties that were paid can still be abated, and the refund claim must generally be made within the refund statute of limitations.