Taxpayer owed federal income taxes for tax years 2019 and 2020. Taxpayer was not able to fully pay their tax debt when it was due, causing accrual of substantial failure-to-pay penalties. Taxpayer eventually fully paid the tax debt but sought to recover a refund of the penalties paid. DeWitt Law represented Taxpayer before the IRS. DeWitt Law filed a claim for refund with the IRS, arguing that Taxpayer qualified for abatement of failure-to-pay penalties due to reasonable cause and COVID-related penalty relief under IRS Notice 2022-36. The IRS granted the claim and refunded the Taxpayer $141,854.73 in failure-to-pay penalties.