Dec 11, 2017 · For some simple penalties—such as a First Time Penalty Abatement—a phone call to the IRS is almost always sufficient to get the penalty abated (and much faster than waiting for the IRS to process a letter). For more complex issues—such as requesting an abatement due to reasonable cause—a letter is the better option to clearly lay out an ... Aug 07, 2019 · There, the Tax Court agreed with the respondent that “first-time abatement procedures are a form of administrative, not judicial, relief.” Id. at 6, 8. The Internal Revenue Manual itself, in the first line describing the First Time Abate program, states “the IRS provides administrative relief from the following penalties . . .”