Client took it upon himself to file his own Form W-2 and 941s.
-He received a notice from the IRS/social security department that he didn't file his W-2s. He ignored.
-They sent him a letter requesting the information and indicated a potential penalty of $100,000. He ignored until a few months after a response was due. We responded to the notice and provided the filed Form W-2s that he is adamant that he filed.
- Client received a notice assessing a penalty of $100,000. He provided us the notice several days after it was due. We responded to the notice referencing our prior letter.
The penalty is under Section 6721(e) and for Failure to File Forms W-2 - Intentional Disregard. I don't believe FTA is available. Is reasonable cause a suggestion? Our position has been that he has filed the W-2s, but it doesn't really matter. He filed the Form 941s but they cannot match to a filed Form W-2.
Any suggestions? Thanks in advance!