Question on late filings. 5500-SF filed 22 days late for 2019 calendar year plan. TPA withheld filing thru EFAST until invoice paid for filing fee, so that was reason plan was late in filing. Plan is 403(b)(7) ERISA plan, but further complicated that 12/31/2019 plan year was last filing, since plan terminated and now has zero balance. 5558 was filed and dated by plan sponsor appropriately. Plan sponsor received CP-220 notice from IRS for $5,500+interest ($250 per day plus interest).
At this point, I see responses indicating DFVCP is preferable. Is Form 843 requesting abatement becoming an issue? Thought COVID period might be good reason to ask for full abatement via the 843, especially since this 2019 filing is last one for this plan and delay caused by TPA. Any thoughts on 843 vs DFVCP to mitigate this penalty amount?
