Doesn't hurt to try calling the practitioner hotline and request it. Get a POA signed first and then call the IRS to abate it (and be near a fax machine for that POA). They'll tell you if it meets the criteria or not. That's probably the easiest thing to do. If they say no, then try reasonable cause. Also, try calling them as soon as they open. I'm on the west coast so I have to call at 5 am my time in order to have a slight chance of getting on hold instead of the "too busy, so sorry" message before they hang up.