LLC filed election for treatment as a C corp for tax purposes on Form 8832. We filed the C corporation return, and we just received a notice that the return was rejected because they did not receive Form 8832. It turns out the LLC had one of their secretaries mail in the form, and they failed to mail it certified, which I believe is true. Since we can't prove timely mailing with a certified mailing receipt, I am filing a new Form 8832. Reasonable cause is that LLC intended to file 8832, and in fact did file the Form, but apparently the IRS never received it. The secretary failed to file the form by certified mail, so no proof of mailing is available. Do we think this passes muster for reasonable cause?