Irm 1.2.1.4.2 File

According to IRM 1.2.1.4.2, the authority to administer oaths and receive evidence is not universal across all 80,000+ IRS employees. It is specifically granted to the following positions (and their authorized delegates):

: To qualify for relief under this IRM section, a taxpayer must demonstrate they exercised "ordinary business care and prudence" but still could not meet their tax obligations. Case-by-Case Analysis irm 1.2.1.4.2

Did the "reasonable cause" event occur during the period the taxpayer was supposed to be filing or paying? According to IRM 1