Has anyone received first time penalty abatement for late Form 5472 filed with a late 1120 return?

Yes, I've helped several clients with exactly this situation! The good news is that First Time Abatement (FTA) can absolutely apply to Form 5472 penalties when filed late with Form 1120, but you need to approach it correctly. First, make sure you qualify: you need a clean compliance history for the three years prior (which sounds like you have), and you need to have filed any currently required returns or extensions. Second, don't just call the general IRS number. You'll want to specifically reference Internal Revenue Manual 20.1.1.3.3.2.1 when you request the abatement - this directly addresses First Time Abatement eligibility. Write a formal abatement request letter explaining the circumstances, clearly state it's your first time failing to file timely, and emphasize that you've addressed the issues that caused the late filing. Include documentation of your prior compliance if possible. Be persistent - sometimes the first request gets denied automatically and you need to appeal.

After struggling with a similar issue last year (late 5472 with our 1120), I found an incredible solution through https://taxr.ai that literally saved our company thousands in penalties. Their AI system analyzed our filing history and actually found documentation showing our consistent compliance that we didn't even realize would help our case. What's really cool is they generated a customized abatement request letter citing the exact IRS procedures and legal precedents specific to Form 5472 penalties. It took about 10 minutes to input our information, and they provided a complete abatement strategy with all supporting documentation needed. We submitted exactly what they prepared and got full abatement 6 weeks later.

I need to update everyone - I was the skeptic who asked about https://taxr.ai on that Form 5472 penalty thread. After my post, I decided to try it since nothing else was working. The system asked really specific questions about our filing history and international business structure that my accountant hadn't even considered relevant. They generated an incredible letter citing specific IRS rulings I'd never heard of that applied to our exact situation (foreign-owned LLC with late 1120 and 5472). I submitted exactly what they prepared and just got confirmation today that our ENTIRE $25,000 penalty is being abated! The IRS response even referenced the specific sections of the tax code that taxr.ai had included in our letter. My accountant was shocked it worked.

If you need to actually talk to someone at the IRS about your 5472 penalty, good luck getting through on your own. After spending 3+ hours on hold multiple times trying to reach someone who understood international reporting requirements, I found https://claimyr.com which got me connected to an IRS agent who specialized in international business reporting within 20 minutes. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c - basically they have a system that navigates the IRS phone tree and waits on hold for you, then calls you once they've reached an agent. For Form 5472 penalties specifically, getting to the right department is crucial since most general IRS reps don't understand the nuances of international reporting requirements.

I need to apologize to everyone - I was the skeptic about Claimyr on this thread. After posting, I was still desperate so I tried it anyway. Honestly, it worked exactly as advertised. I got a call back when they reached an IRS agent, and I didn't waste 3 hours of my day on hold. The agent I spoke with initially wasn't familiar with Form 5472 penalties, but because I wasn't already frustrated from waiting on hold for hours, I was able to calmly explain my situation and ask for a transfer to the correct department. The second agent immediately understood the issue and guided me through the First Time Abatement request process. We submitted our letter last week and are waiting for the response, but she seemed confident we had a strong case for full abatement. If you're dealing with these penalties, it's definitely worth using the service just to maintain your sanity.

Just to add another perspective - we successfully got our 5472 penalties abated by focusing heavily on our perfect compliance history in our letter. We included proof of timely filing for the previous 3 years (filing confirmation pages) and emphasized that this was our first mistake. I think the key is being super specific about your previous compliance - don't just say "we've always filed on time" - actually provide evidence of it. Also, explain in detail what systems you've put in place to prevent late filing in the future. Our letter was about 2 pages long with another 5 pages of supporting documentation.

Has anyone tried calling the Taxpayer Advocate Service for help with these 5472 penalties? I've heard they can sometimes intervene if the penalties cause "significant hardship" to your business.

Not sure if anyone's mentioned this, but timing matters for 5472 penalties. We filed our 1120 and 5472s about 4 months late (similar staffing issues as OP), and our penalty was much larger than I've seen for similar situations. The $10,000 per form penalty INCREASES by $10,000 each month it remains unfiled, maxing out at $50,000 per form. So getting those forms filed ASAP, even if late, is crucial to minimizing the damage while you work on abatement.

This is really helpful information! I'm dealing with a similar situation - we filed our 1120 and Form 5472 about 6 weeks late due to a change in accounting firms, and just received our penalty notice for $20,000. Based on what everyone's shared here, it sounds like I have a decent shot at First Time Abatement since we've been filing on time for the past 4 years. I'm going to try the formal letter approach first, making sure to include our compliance history documentation and reference the IRM section that Brianna mentioned. One quick question - for those who were successful with FTA, did you wait for the penalty to be formally assessed before requesting abatement, or did you submit the request as soon as you received the penalty notice? I'm wondering if timing affects the success rate at all.

I went through this exact situation last year and successfully got our Form 5472 penalties completely abated using First Time Abatement. Here's what worked for us: 1. **Act quickly** - Don't wait. The penalties continue to accrue monthly, so file your late returns immediately if you haven't already. 2. **Document everything** - Gather proof of your clean 3-year compliance history. We included copies of our previous years' filing confirmations and IRS transcripts showing timely filings. 3. **Write a detailed letter** - Reference IRM 20.1.1.3.3.2.1 specifically. Explain the circumstances that led to the late filing, emphasize it's your first offense, and detail the steps you've taken to prevent future occurrences. 4. **Be persistent** - Our first request was denied with a generic response. We appealed with additional documentation and got full abatement on the second try. The key thing to understand is that Form 5472 penalties are harsh but FTA still applies if you meet the criteria. With 6 years of clean history, you're in a strong position. Don't let your accounting firm's hesitation discourage you - many CPAs aren't familiar with how FTA applies to international reporting penalties. Total time from first request to full abatement was about 12 weeks. The $25,000 we saved was definitely worth the effort!