Dishonored Payment Penalty

Church secretary submitted EFTPS payroll tax deposit with a couple extra zeros. She couldn't cancel payment because it was scheduled for the next business day. She requested stop payment at the bank and now they have a penalty assessed for the returned payment based on the inflated amount. Do you think first time penalty abatement is the best route? Penalty is $2,500.

Can’t use First Time Abate for this penalty. Must establish reasonable cause. See IRM 20.1.10.7.3

https://www.irs.gov/irm/part20/irm_20-001-010r#idm139650230502304

Yeah. I was hoping for leniency. Believe it or not, they have granted it a few times.