The situation I am running into is this. I have a partnership client in which one of the partners bought out the other in September 2020. This led to the partnership being terminated in September. I was not aware of this until the taxpayer brought in their tax information in February 2021. As a result, the return was technically filed late. I made the partners aware that they might be receiving a tax notice for this and to let us know if they do.
Client recently brought me in a notice showing that there was an overdue tax account for the partnership that was now being sent to collections. After asking them to take a look, they brought in an original notice dated in March assessing the late filing penalties.
My plan was to request an abatement of this penalty either under Rev Proc 84-35 or the First Time Abatement Waiver. Is it possible to do this with the account in collections? If so, would I follow the normal procedures to request the abatement?