1065 Late filing penalty - advise on abatement request

[Noel-Accountant]

Hi,

A new client comes to me for filing taxes on their partnership (3 partners and less than $10,000 on balance sheet) formed in late 2019.  Unfortunately they did not file their 2019 and 2020 tax returns, or any extensions.  Now both years' tax returns are late.  With COVID, everything was thrown out of whack.  I know the First Time Abatement should be used for the 2019 tax return since it's the one with heaviest penalties.  Reasonable cause for 2020?  Any advise on how to minimize on the penalties and any other strategies would be appreciated.  

Also, should penalties be calculated on the tax return?  Or wait for IRS to issue penalties letter and then start the abatement request?  I can't seem to find where to enter the filing date on Lacerte anyway.  Partners' individual 2019  1040 did not include the K-1 losses, when should the partners amend their personal tax returns?  Their individual share of K-1 losses is about $100.  

Thank you!

[Channell6]

For 2020, you should be able to claim the penalty waver if everyone filed their personal return on time. Search Revenue Procedure 84-35