Edward Flume was looking at penalties for failing to file Forms 5471 from 2001 through 2009, with the total penalties the IRS was looking to collect over that time amounting to $110,000.  In the case of Flume v. Commissioner, TC Memo 2017-21 the taxpayer argued as one defense that he should be excused from any penalties based on reasonable cause for reliance on a tax professional.

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