Taxation · 08/05/2025

This article focuses on addressing late filing of Form 3520, emphasizing the role of a 'reasonable cause explanation' in penalty abatement. Using the real-life case of Wrzesinski, it analyzes how to prepare a comprehensive appeal to seek IRS understanding and avoid or reduce substantial penalties resulting from delayed reporting of foreign gifts. It provides guidance for taxpayers facing similar challenges, offering insights into crafting a persuasive argument for penalty relief based on legitimate reasons for the late filing.