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  1. Renafesq
    I have a client ALE who has not offered coverage to any of its FTEs or FTE equivalent. Of course they have now received a 226-J letter for 2016 because 8 ees have received a PTC on the Exchange. Their argument is that they could not afford to offer coverage because 2018 is the first year they turned a profit (they took over a company in 2015 and never offered coverage). I'm just curious to know if anyone has successfully made a hardship argument on behalf of a client who has never offered coverage to their employees. Of course I am requesting W2s from the client to make sure the IRS did not mistakenly offer the PTC to these employees, but I'm afraid that they are going to get hit with penalties for the past 3 years and likely go out of business. Thank you!
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