Abatement of $150,000 Late Filing Penalty

Letter comes in from IRS. $150K penalty.  My advice has always been:

1) Amend 5500 to check DFVC box

2) Do a DFVC filing and pay the user fee

3) Write the IRS and ask them to abate because you fully complied with DFVC.

Is that what people are still doing?  Firs time I've had to do this with a 150K penalty so I wanted to double check.

austin3515, the procedures have not changed. What you described worked for my client a couple of years ago.

I had another attorney say the same thing!  Great news, thanks!

As a follow up on this, is anyone aware of instances where this has been denied by IRS?

On the IRS website, they state that the IRS will generally waive penalties for filers who satisfy DFVCP (and also file form 8955-SSA and meet the requirements of Notice 2014-35).  

In the DFVCP FAQ, DOL states that the IRS may provide relief and that PBGC has agreed to provide relief where conditions of DFVCP have been satsfied.

You have to love the certainty...