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Reasonable-cause self-check

Twelve yes-or-no questions taken from the checklist the IRS penalty unit works through on a Notice 972CG response. The result tells you which items would get a Letter 1948-C asking for more, which would be denied without judgment, and which weaken the substance.

Basis IRM 4.19.25.8 and 4.19.25.8.3 (Aug. 25, 2025); IRM 20.1.7.12.1 (Mar. 13, 2025); Treas. Reg. 301.6724-1Privacy runs in your browser; nothing you enter is sent or stored

Answer for the response you are about to send. "Not applicable" counts as yes.

Is the statement signed by an officer (or a partner), not by a preparer, vendor or AP staff?
IRM 4.19.25.8(3); 20.1.7.12.1(6)
Does it contain a penalties-of-perjury declaration (or did you sign the disagreement block on the notice itself)?
IRM 4.19.25.8(4)
Does it cite the provision relied on (Treas. Reg. 301.6724-1) and set out all the facts?
IRM 4.19.25.8(3)
Does it address every failure code on the notice (late, TIN, paper), not just the most expensive one?
IRM 4.19.25.7.2; 20.1.7.3.3
Does it say, with dates, what you did when you discovered the error?
IRM 4.19.25.8(6)
Does it say what you changed so the failure will not recur, and can your next filing season back that up?
IRM 4.19.25.8(7); 20.1.7.12.1(12)
Does it name a mitigating factor or an event beyond your control from the IRS list, with the document that factor requires?
IRM 4.19.25.8(8)-(11); 20.1.7.12.1(11)-(23)
If you received a 972CG in a prior year for the same failure, does this statement show the error rate went down?
IRM 20.1.7.12.1(12)-(13)
For TIN failures: were the annual solicitations made by mail or telephone (not email or portal), and can you produce the dated letters and mailing log?
IRM 4.19.25.8.3(4)-(8)
For late-filing failures: do you have a certified or registered mail receipt, or the FIRE/IRIS acknowledgment, as proof of the filing date?
IRM 4.19.25.8.1(10)-(12)
Have you avoided citing First Time Abate, misdirected mailing to a state agency, or a second e-file hardship waiver as your reason?
IRM 4.19.25.8(1), 8(12), 8.2
If a representative is responding or appealing, is there a Form 2848 (not 8821) listing Civil Penalty, the form series and the years?
IRM 4.19.25.17.3.1; 20.1.7.4

What the three groups mean

Formalities are checked before any facts are read. A missing signature, jurat or provision, or an unaddressed failure code, gets a Letter 1948-C on a current-year case (30 days to cure, and the IRM allows only one suspense) or a closed file on a reconsideration (IRM 4.19.25.8(3) to (4), 4.19.25.13, 4.19.25.17.1.3).

Substance is the two-part reasonable-cause test as the examiner scores it: did you react timely, did you prevent recurrence, and is there a mitigating factor or an event beyond your control from the list the examiner is given. If you are silent on prevention, the examiner pulls your next year's filing and answers for you (IRM 4.19.25.8(6) to (7)).

Denied on sight are the things the IRM's decision tables resolve without judgment: annual solicitations by electronic means ("Deny the request for relief. Assess the penalty."), a plain postage receipt as proof of filing, First Time Abate, and an 8821 where a 2848 is required.

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