IRM 20.1.1: Introduction and Penalty Relief Legal Reference Brief

IRM 20.1.1 describes penalty administration and relief categories. Reasonable cause is a facts-and-circumstances determination, not an automatic waiver whenever hardship or illness is alleged.

Source checked: 2026-10-13 · Official IRS manual

The IRM is internal IRS procedural guidance, not the tax law. This selected reference is educational, not a complete legal opinion. Verify current law, guidance and case-specific deadlines.

Authority and categories The section addresses civil penalty policy, statutory exceptions, administrative waivers and reasonable cause. The applicable penalty statute matters; examples include IRC § 6651 for failure to file/pay and § 6656 for deposit penalties.

Reasonable cause The IRS considers whether the taxpayer exercised ordinary business care and prudence but nevertheless could not comply. The event, its timing, effect on compliance and corrective actions need to be evaluated together.

Administrative relief Administrative-waiver criteria are distinct from reasonable cause. Consult the current First Time Abate provisions and any newer IRS administrative guidance applicable to the tax year. Relief may differ across penalty types and does not automatically eliminate the underlying tax.

Practical limits Illness, casualty or other disruption is evidence to examine, not a guaranteed outcome. Determine whether a penalty was correctly assessed before requesting discretionary relief. Current law and specific penalty sections may impose additional requirements.