Discussion:1065 Late filing "recovery" penalties?

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Discussion Forum Index --> Basic Tax Questions --> 1065 Late filing "recovery" penalties?
Discussion Forum Index --> Tax Questions --> 1065 Late filing "recovery" penalties?

Jmatt (talk|edits) said:

2 February 2009
LLC is out of business for several years. Way, way late 1065s had to be filed to determine K-1 income for personal 1040s for those years. IRS is now trying to collect late filing penalties from the failed LLC. It's gone. They are not hounding him personally.

Question:

Does a 'recovery penalty' exist for for the responsible party fo late filing as there is for payroll trust fund taxes?

Can't find anything on this. Any hints would be appreciated.

DouglasHolbrook (talk|edits) said:

2 February 2009
Check REv Proc 84-35 (?) for abatement of the penalties.

Jmatt (talk|edits) said:

2 February 2009
That was my firts thought. However, he really doesn't qualify for Proc 84-35 because his personal return was filed years late as well.

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