At what point does a Form 5472 penalty case become serious enough for Form 911 and the Taxpayer Advocate Service?
I do not want to over-escalate too early, but I also do not want to be stubborn about staying in ordinary channels once the case is clearly causing real damage. The company has already sent documents, waited through normal processing, and is now dealing with an operational mess because the issue keeps hanging open. That makes me wonder whether Form 911 is meant exactly for this kind of breakdown.
I am looking for a sober standard, not a dramatic one. If TAS is really for cases involving hardship, threat, or abnormal delay after normal channels have failed, I want to know how to judge whether my case has crossed that line.
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