Many people pay the penalty to make it stop, or send one letter and hope. There is a better route. Sometimes it is a phone call and knowing which IRS unit to call and when. Often it is a well-organized written request, clearly explaining and documenting the facts and legal authority, sent to the correct IRS campus.
A focused review can identify the strongest route before time and options narrow.
Free penalty notice reviewRoss Martin, JD, authorized to represent taxpayers before the IRS.
Often, yes. A penalty notice is an opening position, not a final assessment. More than one route frequently applies to the same account, and the strongest is usually not the one most people reach for.

IRS systems can use the wrong due date, post a payment to the wrong period, miss a withholding credit, or assess a penalty without the facts and legal authority that support relief. Paying immediately or sending a generic letter can leave the strongest argument unused.
The right request, delivered the right way to the right unit, can change the outcome.
Review my noticeFirst-time abatement and reasonable cause requests, built on the right authority and backed by the right documentation.
A letter is not always the answer, and neither is a call. We match the request to the best medium and send it where that penalty is actually worked.
When the IRS posts a payment to the wrong period or date and interest keeps compounding, we guide the IRS through correcting the record.
FIRPTA and 1042 withholding, foreign asset reporting, and credits the IRS failed to match, tracked through to the refund.
Tell us what the IRS sent and give us a short summary of what happened.
We review the notice and relevant account transcripts to identify what generated the assessment.
We tell you whether the fastest path is a documented request, an account correction, or the right call to the right unit.
You are not committing to anything by asking. The first review tells you whether you have a case, and if there is no realistic path we will say so.

Ross Martin, JD, is an international tax consultant authorized to represent taxpayers before the IRS. His practice centers on cross-border consulting, compliance, and IRS controversy, including planning and structuring advice, penalty abatement, international information return filings, and correcting account errors that generate assessments on returns filed on time.
Often, yes. Which route fits depends on the penalty, account history, and what the transcript actually shows.
Nothing. Send the notice and a short summary. The review identifies whether there is a case worth pursuing and which route appears strongest.
The full notice, including its number and date, plus a short description of what happened. Account transcripts often matter as much as the return.
It varies widely. An account correction can post quickly, while a documented written request may take months. Information return penalties can take longer still.
Payment does not forfeit the claim. You can request abatement and refund, subject to the refund limitations in section 6511, generally three years from filing or two years from payment, whichever is later.
A denial is not always the end. Denials often turn on how the request was framed, whether the controlling provision was identified, and whether the documentation supported the facts.
Yes. Cross-border matters are the core of the practice, including US citizens abroad, foreign corporations with US filings, withholding, and foreign asset reporting penalties.
Once authorized, we can speak with the IRS, obtain transcripts, and submit and negotiate requests. This is a tax practice rather than a law firm and does not include court representation.
A short summary is enough to start. No cost, no obligation, and a straight answer on where you stand.
Send us your notice