We fixed the Form 5472 problem after the notice but before the 90-day point. What proof matters most if the IRS still pushes continuation penalties?
Once we realized the notice could turn into an additional penalty timeline, we stopped debating and repaired the underlying problem as fast as we could. The corrected package was sent, the records were organized, and the file is genuinely much cleaner now than it was on the day the first notice arrived. My worry is that the IRS may still act as though the failure kept going longer than it really did.
What I want to know is which proof matters most once the company has already cured the problem before the continuation window should have hardened. If there is a specific way to show the date the gap actually closed, I want that front and center in the response file.
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