Is an appeal against a penalty notice for failure to file 3520-A more likely to succeed if made by a professional, rather than me just adopting Gary Carter's template? My situation is the same as mentioned in Gary's blog of November 2019.
In 2019 I filed for an extension. On advice my a tax attorney, I filed a substitute 3520-A as an attachment to my 3520. Last week I got a penalty notice for $10,000. I don't want to go back to the advising attorneys. There is only one foreign "trust" in question and that's for the UK pension fund I had while working in the UK until 2001. I have made no contributions to it, nor taken any distributions since moving to the US.