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A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts.
84-35 doesnt apply to S corps. In addition to these factors, your client must demonstrate reasonable cause for consideration of abatement of the penalties. Rev Proc 84-35 states that if reasonable cause can be shown, then they may abate the penalty.
Revenue Procedure 84-35 provides that in order to qualify for the relief provided in the revenue procedure, the partnership, or any of the partners, must establish, if so requested by the IRS, that all partners have fully reported their shares of the income, deductions, and credits of the partnership on their timely
Revenue Procedure 84-35 Reasonable cause for failure to file a timely and complete partnership return will be presumed if the partnership (or any of its partners) is able to show that all of the following conditions have been met: The partnership had no more than 10 partners for the taxable year.
A revenue procedure is an official statement of a procedure published in the Bulletin that either affects the rights or duties of taxpayers or other members of the public under the Internal Revenue Code and related statutes, treaties, and regulations or, although not necessarily affecting the rights and duties of the

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The late payment penalty is 0.5% of the tax owed after the due date, for each month or part of a month the tax remains unpaid, up to 25%.
IRS Letter to Request First-Time Penalty Abatement. To Whom It May Concern: We respectfully request that the [failure-to-file/failure-to-pay/failure-to-deposit] penalty be abated based on the IRSs First Time Abate administrative waiver procedures, as discussed in IRM 20.1. 1.3.

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