For tax practitioners that have a small partnership with late filing penalties, an abatement is possible under the "small partnership exception".
Here is the verbiage, and the attachment below has the docs you need. Good luck.
(Courtesy of Christy Pinheiro, EA ABA, Please note that the following is NOT tax advice and is designed for enrolled practicioners to use).
SAMPLE RESPONSE LETTER:
TO WHOM IT MAY CONCERN:
The above captioned taxpayer is a small partnership deemed to meet the reasonable cause test under IRC 6231(a)(1)(B). The partnership is a domestic partnership consisting of ten or fewer partners, which equally share partnership items. The partners have filed timely tax returns.
Please note the attached documents that explain the tax code section that requires the abatement of a penalty in this case.
1. SCA 200135029,
2. Revenue Procedure 84-35,
3. Portions of a Memo from TIGTA recommending stronger sanctions against late filed partnership returns AND the Commissioner’s disagreement with the TIGTA recommendation, (attached below) and
4. A portion of the Penalty handbook noting the penalty relief available to small partnerships
For the above named partnership, please abate all penalties.
XXX CPA, EA (etc)