I am wondering if anyone has had luck arguing for removal of a failure to file penalty?  The penalty sounds cut/dry but the pandemic did create an odd situation for a client of mine.  I have a draft of an argument written and can include an obituary as support.  I am wondering if I should have my client send in a check to cover the penalty while we wait for an answer, or if that is an admission of accepting the penalty?

Thank you, 

Amy