CP162

A CP162 charges a partnership (or REMIC) a penalty for not filing its return electronically when e-filing was required. It's a compliance-format penalty — about how the return was filed, not what was in it — and it has defined outs.

“E-filing was required and didn't happen, so here's the penalty. If the partnership had fewer than 101 partners, or had a waiver for the year, an authorized officer or partner can call and we'll discuss removing it. Reasonable-cause waiver requests in writing are also possible.”

Paying by the printed date stops interest. But the exceptions are checkable before paying: the under-101-partners rule and waivers are matters of record, and reasonable cause covers legitimate inability to e-file.

• The notice
• Evidence of the partner count during the year, if under 101
• Any e-file waiver granted for the year
• The facts behind the paper filing, for a reasonable-cause statement

• Determining whether the penalty even applies under the partner-count and waiver rules
• Making the authorized call — the IRS specifies who may speak for the entity
• Writing the reasonable-cause waiver request
• Fixing the e-file setup so it never recurs