IRM 1.2.1.4.2 is only a few paragraphs long. It does not contain colorful prose or dramatic legal theories. Yet, for the taxpayer, the practitioner, and the IRS employee, this tiny delegation of authority is the linchpin that transforms informal conversations into sworn testimony.
If you are referring to the :
When essential documentation is destroyed or unavailable through no fault of the taxpayer. irm 1.2.1.4.2
To understand this section, let’s break down the numbering system:
The existence of this policy within the Servicewide Policy Statements serves several functions: If you are referring to the : When
While IRM 1.2.1.4.2 grants broad authority, it does not grant unlimited power:
Here is what I can infer and how I can help: Common reasons that may qualify as reasonable cause
IRM 1.2.1.4.2 is a specific section of the Internal Revenue Manual (IRM) containing Policy Statement 3-2
: By declaring these retroactive assertions "impractical," the IRS directs its limited enforcement resources toward more current and high-impact compliance areas.
The manual directs IRS employees to evaluate relief requests on a . Common reasons that may qualify as reasonable cause under this policy include:
The core objective of this provision is to support the IRS's mission of encouraging voluntary compliance by providing a fair and consistent framework for removing penalties when taxpayers make a good-faith effort but face circumstances beyond their control.