Filing Post ACA Penalty Returns

Technical topics regarding tax preparation.
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15-Feb-2020 1:19am
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New Jersey
I have a client who's in the process of trying to get exemptions for the ACA penalties for the years that they were in effect- up to and including 2018. These are problematic returns that I'm hoping to research and file sometime soon, but it's going to take time. Financially, 2019 is a pretty straightforward year for him (only two W2s, nothing else). I'd like to file 2019 to try and get him a stimulus check, but I'm concerned that, by filing 2019, I might somehow limit the options for approaching the previous years.

Because the penalties were no longer federally enforced in 2019, that should, for lack of a better word, quarantine the mess to the previous returns, correct? Am I missing something? I don't want to file 2019 to get $1200 only to find out later that filing 2019 somehow impacted his previous years penalties adversely (which could end up being cumulatively quite substantial if he can't squeeze into one of exemption categories).
 

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