Late filing Penalty

[hunter001]

We have been receiving IRS notices in regards to our client's 2007 and 2008 filing. We receive the correspondence because it is part of our procedure to file the Form 5500 using our address as we are a bank and are appointed trustee of the plan for most of our clients. We have tried to get in contact with our client in order for them to file the forms and respond with a reasonable cause but they have been unresponsive. Now the IRS is wanting them to pay a hefty penalty. Im thinking my next step is to contact the IRS and have them start sending the notices directly to our client. Any suggestions?

[12AX7]

Unless I was the plan sponsor, I would not not consider putting my address on the 5500. I would notify the IRS of the address change so that I don't have to see an ex-client's business with the IRS. Good luck!