Represented taxpayer who allegedly failed to file Form 3520 to report receipt of a foreign gift. The IRS automatically assessed a nearly $100,000 penalty plus interest and the taxpayer, through their tax return preparer, unsuccessfully challenged the assessment for three years. ATL was engaged to file a Protest and proceed through the administrative appeal process. Despite an seven month wait for the matter to be assigned to an Appeals Officer (AO), ATL resolved the matter in one phone call with the AO obtaining a full abatement of the penalty and interest.
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