Receive a framework to recognize when an IRS penalty can and cannot be remedied with your efforts. We’ll separate statutory exceptions, administrative waivers, including first-time abatement (FTA) and true reasonable cause. You’ll learn how the IRS actually evaluates facts under the ordinary business care and prudence standard, what evidence counts most, and how to route requests to maximize a yes on the first pass or on appeals. We will dissect Tracy v. Commissioner, a small-case decision where the court explained reasonable cause and abated §6651 late-file and late-pay penalties for elderly, disabled attorney winding down his practice who had office procedures in place to catch normal errors.