Has anyone successfully received a First Time Abatement for Sec 6038A penalties on late filing a blank Form 5472?

The Form 5472 penalties are indeed extremely harsh. Unfortunately, First Time Abatement relief traditionally doesn't apply to international information reporting penalties like those under Section 6038A. FTAs typically only apply to failure to file, failure to pay, and failure to deposit penalties. However, that doesn't mean you're completely out of options. Even without formal "reasonable cause," you might consider requesting penalty relief through other avenues. The IRS sometimes shows leniency if you can demonstrate a good faith effort to comply, especially if the form was blank (no reportable transactions). You could try writing a detailed letter explaining your circumstances, acknowledging the mistake, and emphasizing that the form was blank with no transactions to report. Sometimes highlighting the disproportionate nature of the penalty compared to the infraction can help your case.

After fighting with the IRS for months over international reporting penalties (different form, similar nightmare), I found an incredible solution with https://taxr.ai - they actually specialize in penalty abatement cases just like yours. I uploaded my penalty notice and they immediately identified multiple arguments I could use that weren't even on my radar. Their system analyzed my situation and showed me exactly what to include in my abatement request letter. The best part was they found actual precedent cases where the IRS had granted relief for similar situations with Form 5472 penalties. I wasn't even thinking about citing precedent, but apparently it makes a huge difference.

I was skeptical about taxr.ai when I first saw it mentioned here, but I was desperate with a $10,000 FBAR penalty hanging over my head. I decided to give it a try and I'm honestly shocked at how well it worked. The system immediately identified three specific legal arguments for my situation that neither my accountant nor I had considered. It pulled up actual case precedents where taxpayers won similar cases and even referenced specific sections of the Internal Revenue Manual that applied to my situation. I followed their guidance exactly, submitted the letter they helped me create, and just heard back last week that my penalty was completely abated! What impressed me most was how they broke down which arguments work for which specific types of international penalties - they clearly have deep expertise in this niche area.

If you need to actually talk to someone at the IRS about this (which you probably will), good luck getting through. I spent WEEKS trying to get a human on the phone about my penalty issue. Then I found https://claimyr.com and watched their demo at https://youtu.be/_kiP6q8DX5c - they basically wait on hold with the IRS for you and call you when they get a human. I was at my wit's end dealing with a $15K penalty for a different international form. My abatement letter had been sent but was apparently sitting in a pile somewhere. Using Claimyr, I got through to an actual IRS agent who looked up my case and expedited the review. Without that call, I'm convinced my letter would still be sitting there unprocessed.

I owe everyone here an apology. After calling BS on Claimyr in my comment earlier, I was still desperate to get through to the IRS about my own penalty issue (not Form 5472, but a similarly ridiculous penalty for a small mistake). I gave the service a shot, and I'm eating my words now. Not only did they get me through to the IRS in about 2 hours (compared to my previous attempts that never succeeded), but the agent I spoke with was actually able to help. I explained my situation, and they transferred me to someone in the right department who reviewed my case on the spot. Long story short - my $12,500 penalty was reduced to $1,250 because the agent recognized there were mitigating factors. I never would have gotten this resolved without actually speaking to someone. Sometimes being a skeptic means I miss out on solutions that actually work.

I'm a tax preparer (not a lawyer though) and have seen several Form 5472 penalty cases. Here's what most people don't realize: the IRS is incredibly strict about these international information forms because they're trying to crack down on offshore tax evasion. Even though reasonable cause is the standard relief mechanism, I've seen clients have success with detailed letters explaining their situation even without formal reasonable cause. The key is to demonstrate: 1. This was your first time dealing with this requirement 2. The form was blank (this is important - no tax revenue was at risk) 3. You're committed to timely compliance going forward

Has anyone tried requesting a supervisor review for these types of penalties? I've heard that sometimes lower-level IRS employees don't have the authority to abate large penalties, but their managers might.

I went through this exact situation with Form 5472 penalties last year - $25K for a blank form filed just 3 weeks late. I was told by multiple sources that FTA doesn't apply to international reporting penalties, but I decided to try anyway since I had nothing to lose. I wrote a detailed letter explaining that this was my first time dealing with Form 5472, emphasized that the form was completely blank with no reportable transactions, and included documentation showing my otherwise perfect compliance history. I also highlighted how the penalty was completely disproportionate to the infraction - no tax revenue was at risk. To my surprise, they granted a full abatement! The letter I received back specifically mentioned that while FTA doesn't technically apply to Section 6038A penalties, they were exercising discretionary relief based on my compliance history and the fact that no actual reporting was required. My advice: don't let people tell you it's impossible. Write that letter, be thorough about your circumstances, and emphasize the blank form aspect. The worst they can say is no, but you might be surprised like I was.

I just want to add another perspective here - I'm a small business owner who went through this exact nightmare with Form 5472 penalties two years ago. The $25K hit for a blank form filed late was devastating to my cash flow. What ultimately worked for me was a combination approach: I used the penalty analysis tools that others mentioned here to craft a really strong abatement letter, but then I also made sure to actually get through to the IRS to follow up. The written request alone wasn't enough - it was sitting in limbo for months until I was able to speak with someone who could actually review my case. The IRS agent I spoke with acknowledged that blank Form 5472 penalties are often viewed more leniently because there's no actual tax revenue at stake. She was able to see my compliance history and agreed that the penalty was disproportionate. I ended up getting a 90% reduction - not a full abatement, but $2,500 is a lot more manageable than $25,000. My advice is don't give up after the first rejection. These penalties are so harsh that even IRS agents sometimes recognize they're excessive for procedural violations with no substance behind them.

I'm dealing with this exact same situation right now - got slapped with a $25K penalty for filing Form 5472 about 2 weeks late, and it was completely blank with no transactions to report. Reading through all these responses is giving me hope that I'm not completely screwed here. What strikes me is how many people have mentioned that the IRS does seem to recognize these blank form penalties as being disproportionate, even if they won't admit it officially. The fact that multiple people here have gotten significant reductions or full abatements suggests there's definitely room to fight this. I'm planning to take a multi-pronged approach based on what I've learned here: craft a detailed letter emphasizing this is my first time with Form 5472, highlight that the form was blank with zero reportable transactions, and then follow up with calls to make sure it doesn't get lost in the system. The penalty analysis tools mentioned here sound like they could really help me put together a stronger case than I would on my own. Has anyone had experience with how long the whole process typically takes from initial request to final decision? I'm trying to plan my cash flow around this nightmare.

I've been following this thread with great interest as I'm facing a similar situation with Form 5472 penalties. What really stands out to me from all these experiences is that the IRS seems to have more flexibility with these penalties than they initially let on, especially for blank forms. One thing I'm noticing is that successful cases seem to share a few key elements: emphasizing it's your first time dealing with Form 5472, highlighting that the form was blank with no reportable transactions, and demonstrating overall good compliance history. The proportionality argument also seems powerful - a $25K penalty for a procedural violation with no tax revenue impact is genuinely harsh. For those still fighting these penalties, it sounds like the combination of a well-crafted written request followed by persistent phone calls to ensure processing is the way to go. The success stories here are really encouraging - it shows these penalties aren't as set in stone as they initially appear. I'm curious if anyone has noticed whether certain IRS offices or regions are more receptive to these requests than others? Or if there are particular times of year when the IRS might be more willing to consider penalty relief?