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Template · Backup withholding

Corrected Form 945-A cover letter (reply to CP 207)

The reply that stops an averaged deposit penalty: a schedule of liability dates that ties to line 3, sent within the 45 days, before any reasonable-cause request. Read it below, copy the text, print it, or download the .docx for your letterhead.

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Template from tincompliance.com. A cover letter for a corrected record of federal tax liability (Form 945-A, or the line 7 monthly summary) sent in reply to CP 207, CP 207L or Letter 313-C. The IRS averages the year's tax across every deposit date when the schedule is blank, negative or does not tie to the return, and "Reasonable cause cannot be considered or denied on an averaged FTD penalty assessment" until a valid schedule is on file (IRM 20.1.4.18, 20.1.4.26.1, Apr. 17, 2026). Send the schedule within the 45 days on the notice; the averaged penalty assesses systemically at week 15 if a valid schedule has not been input by week 13.

[Company legal name]

EIN: [00-0000000]

[Address on file with the IRS]

[Date]

Internal Revenue Service

[Address or fax number shown on the notice]

Re: [CP 207 / CP 207L / Letter 313-C] dated [notice date]; Form 945 for calendar year [year]; corrected record of federal tax liability enclosed

Dear Sir or Madam:

In reply to the above notice, [Company] encloses a corrected [Form 945-A, Annual Record of Federal Tax Liability / monthly summary of federal tax liability (Form 945, line 7)] for calendar year [year].

1. The corrected schedule

The schedule shows the amount of backup withholding [and other nonpayroll withholding] incurred on each date it was withheld from payments to payees. It does not list deposit dates. The total of the schedule, $[amount], equals the total tax reported on line 3 of the Form 945 for [year] as filed [on [date] / as corrected on the enclosed Form 945-X]. No entry on the schedule is negative.

[Choose one:] (a) The schedule filed with the return was [blank / incomplete / listed deposit dates rather than liability dates / contained a negative entry to reflect a refund to a payee, which is now reported instead on Form 945-X]. / (b) The schedule filed with the return was correct as to dates; the difference from line 3 arose from [rounding / an amount entered in the wrong period]. The enclosed schedule ties to line 3 exactly.

[If deposit status changed during the year:] [Company] was a [monthly / semiweekly] depositor for [year] based on a lookback amount of $[amount] on its Form 945 for [year minus 2]. [The $100,000 next-day rule was triggered on [date], after which [Company] deposited on the semiweekly schedule.]

2. Request

[Company] requests that the proposed averaged penalty be withdrawn and that any failure-to-deposit penalty be recomputed on the basis of the enclosed schedule and the deposits on the account, and that the recomputation (CP 568 or the FTDPN summary) be sent to the address above.

[If applicable:] [Company] will submit a separate request for relief for reasonable cause [or First Time Abate] once the penalty has been recomputed on the corrected schedule, addressing each penalized deposit specifically.

Questions may be directed to [name, title], [phone], [email].

[Signature]

[Name], [Title]

[Date]

Enclosures: corrected [Form 945-A / line 7 summary] for [year]; copy of the notice; [Form 945-X]; [deposit confirmations]

A signature is required only if the total tax changes (IRM 20.1.4.21.2(3)); sign anyway. Oral changes to dates or amounts are not accepted. A corrected schedule can increase the penalty if the real withholding dates are earlier than those on a schedule the IRS had accepted (IRM 20.1.4.21.2(2)); run the Form 945 deposit penalty calculator on tincompliance.com before sending.

How to use it

  • Form 4669 relieves the payer of the tax only when the payee reported the income and paid the tax; it never removes penalties or interest, and is not available where withholding was actually taken and kept. More
  • Respond within 30 days of Letter 6112 or 6112-A; one 30-day extension is available and it is always 30 days (IRM 4.19.26.10.5). An incomplete response does not stop the clock. More
  • List every payee on the IRS's List of Payees with the full TIN, the date it was received and the document it came on. Truncated TINs are rejected. A W-9 dated on or before the payment clears the payee even if the TIN on it is wrong.
  • If any withholding is owed, sign and return a Form 945 with the liability schedule rather than letting the IRS assess; First Time Abate is available only on a return you filed or signed. More
  • Form 4669 from a payee who paid the tax abates the tax only, never penalties or interest; the forms must tie exactly to the IRS's amounts and years.

A general-purpose starting point, not legal advice. Your facts, and your counsel, control what you send.