BobKamman
Level 15

Are you sure he hasn't had to pay any penalties for the three prior years (2020-2022)?  Like a new kid showing up for class claiming to have perfect attendance at the last school.  Trust, but verify.  Anyway, this is what the IRM says about the FTP penalty continuing to accrue.  The abatement isn't finished until the tax is paid.  

"Note:  If the tax is not paid in full on the module that meets FTA criteria, allow abatement of the FTP penalty under the FTA waiver and use reason code (RC) 062 with the TC 271. While the FTA waiver is an administrative waiver and not reasonable cause, the RC 062 will not restrict Master File from continuing to compute the FTP penalty on the unpaid tax and is to be used in this instance only.An open paragraph must be used in Correspondex Letters 168C, 3502C, and 3503C to inform the taxpayer that the FTP penalty will continue to apply to the unpaid tax. After the tax is paid in full, the additional FTP penalty can be removed under the FTA waiver."

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