Irm 1.2.1.4.2 Instant

Failing to submit tax forms by the deadline.

: The IRS acknowledges that it is often impractical to demand payment for these taxes from many prior years if the taxpayer (often a service provider) was not previously aware of the requirement or if the collection effort would be excessively burdensome. irm 1.2.1.4.2

If you are referring to the :

There must be a direct link between the event and the failure to meet the tax obligation. Failing to submit tax forms by the deadline