Anybody used this Rev. Proc? Client's first time filing of form 1065 for 2018 for 2 partners and he wasn't aware of the partnership return deadline. I rather not do a first time abatement which we can use for something else in my client's case, such as underpayment of estimated tax. However, correct me if I'm wrong.
Rev. Proc. 84-35 penalty relief to apply and concluded that it is the same criteria that has been documented in IRM 20.1.2.3.3.1(2):
1. The partnership must consist of 10 or fewer partners. For the purpose of this requirement, a husband and wife (or their estate) filing a joint return is considered one partner.
2. Each partner is either an individual (excluding nonresident aliens), or the estate of a deceased partner.
3. Each partner's items of income, deductions, and credits are allocated in the same proportion as all other items of income, deductions, and credits.
4. The partnership has not elected to be subject to the consolidated audit procedures under I.R.C. §§ 6221 through I.R.C. § 6233 (subchapter C).
5. Each partner reported his or her share of partnership income on his or her timely filed income tax return.