See Special Enrollment Exam Quiz
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SEE PART 3: REPRESENTATION, PRACTICES, AND PROCEDURES
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An enrolled agent's client was assessed a failure-to-file penalty and a failure-to-pay penalty in October 2025 with respect to the client's 2024 Form 1040. The client did not request an extension, filed the 2024 return late in July 2025, and paid the balance due in full at that time. The IRS had imposed an estimated tax penalty under IRC § 6654 with respect to the client's 2022 tax year, and that penalty was paid. Apart from that penalty, the client had no penalties for tax years 2021 through 2023 and timely filed every return for those years. The client asks whether the IRS will waive the 2024 penalties under the first-time penalty abatement procedure.
Which of the following is correct regarding the client's request for first-time penalty abatement?
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