Author: Zaher Fallahi

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Appealing IRS Penalty Abatement Denials: Foreign Disclosure Penalties and Navigating the Appeals Process

Dear Colleagues,

I am pleased to announce that I will be speaking at the upcoming BARBRI/Strafford webinar on , onSeptember 24, 2026, At 10:00 A.M. Pacific / 1:00 P.M. Eastern, Format: Live Webinar with Live Q&A (90 Minutes)

This CLE/CPE course will provide tax attorneys, CPAs, and enrolled agents with a comprehensive and practical guide to navigating the process of appealing an IRS denial of a penalty abatement request. The panel will provide an overview of the significant foreign international information reporting forms (including tax and FBAR filings), their associated penalties, and FBAR the process of administratively requesting abatement requests of penalties. The panel will offer useful tools for compiling and submitting the appeal correspondence and documentation

The IRS continues to aggressively enforce FBAR and foreign information reporting requirements, often asserting significant penalties. This presentation will provide practical guidance on appealing IRS denials of penalty abatement requests, developing persuasive reasonable cause arguments, navigating the IRS Independent Office of Appeals, and effectively presenting the legal and factual evidence necessary to maximize the likelihood of a successful outcome.

If your practice involves international tax compliance, IRS controversy, foreign information reporting, or tax procedure, I hope you will find this program informative and immediately applicable to your practice.

Registration is available through the following link: https://www.barbri.com/course/professional-development/CLE-CPE/appealing-irs-penalty-abatement-denials-foreign-disclosure-p_2026-09-24

https://www.barbri.com/course/professional-development/CLE-CPE/appealing-irs-penalty-abatement-denials-foreign-disclosure-p_2026-09-24

Zaher Fallahi, Attorney At Law, CPA (CA & DC)

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IRS Service Challenges Continue: Persistence Still Pays

irs

Taxpayers and tax professionals continue to experience significant challenges when attempting to resolve matters with the Internal Revenue Service.

A recent report issued by the Treasury Inspector General for Tax Administration (TIGTA) concluded that the IRS referral process between its various business units can result in unnecessary delays, incomplete documentation, and prolonged resolution of taxpayer inquiries.

The report recommends improved documentation, centralized tracking, and more efficient processing to better serve taxpayers.

Our firm has experienced many of these challenges firsthand. Since the beginning of 2026, staffing reductions and increased call volumes have made it increasingly difficult to reach the appropriate IRS personnel.

Although the IRS has made meaningful improvements to electronic account access and online services, many tax matters still require direct communication with the agency. Too often, practitioners are met with the familiar message: “Due to extremely high call volume, please call back later.”

Yesterday was a perfect example. After numerous unsuccessful attempts, I finally reached the IRS Practitioner Priority Service, where an exceptionally helpful representative assisted me in obtaining Account Transcripts for two clients who may qualify for substantial penalty and interest relief under the recent Kwong decision.

Those transcripts were essential because they enable us to identify the precise penalties and related interest for each tax year and timely prepare Protective Claims for Refund and Abatement before the applicable statute of limitations expires. What began as a frustrating afternoon ultimately produced meaningful progress because persistence prevailed.

For taxpayers facing IRS examinations, collection matters, penalty abatements, international reporting issues, transcript requests, or potential COVID-19 penalty and interest relief under the Kwong decision, experienced professional representation has become more important than ever.

While technology continues to improve, many tax controversies still require persistence, strategic advocacy, and effective communication with the IRS.

Zaher Fallahi, CPA, MSA, MBA, Attorney at Law, has represented taxpayers before the IRS for over four decades. From our Downtown Los Angeles and Orange County (Costa Mesa) offices, we represent individuals and businesses throughout the United States and internationally in IRS examinations, appeals, collection matters, international tax compliance, and complex tax controversy cases. If you are experiencing difficulty resolving an IRS matter or believe you may qualify for relief under the Kwong decision, we invite you to contact our office for a confidential consultation.

After representing taxpayers before the IRS for over four decades, one lesson remains unchanged: persistence, preparation, and professional advocacy often make the difference between frustration and resolution.