⚠️HIGH PRIORITYBusiness ComplianceIRC §6651 — Failure to File or Pay

    IRS CP215

    Penalty for Late Business Return

    Your corporation or organization filed late — an IRS penalty has been assessed.

    Deadline

    60 days to respond or request abatement

    Request abatement within 60 days of the notice date. First-time abatement is available for eligible businesses and often eliminates the penalty entirely.

    Respond promptly to protect your options and avoid escalation.

    What IRS CP215 Means

    CP215 is issued when a business return — typically a C-corporation (Form 1120) or tax-exempt organization — is filed late or without all required information. The penalty is typically 5% of the unpaid tax per month, up to 25%, under IRC §6651.

    Unlike the per-partner calculation for CP162 (partnerships and S-corps), the CP215 penalty is based on the corporation's actual unpaid tax balance at the filing deadline. If the tax was fully paid by the due date, the failure-to-file penalty still applies but may be reduced.

    Many CP215 penalties qualify for first-time abatement (FTA), especially for businesses with a clean compliance history. Additionally, if the late filing was due to circumstances beyond your control — disaster, illness, professional advice — reasonable cause abatement may also apply.

    What the IRS Can Do If You Don't Respond

    • Assess failure-to-file penalties of 5% per month, up to 25% of unpaid tax
    • Accrue interest on both the tax and penalty balances
    • Escalate to collection notices if the penalty remains unpaid
    • Coordinate with state tax agencies on compliance issues

    What You Should Do Right Now

    1. 1

      Verify the filing date of your return and compare to the due date (including any extension)

    2. 2

      If you filed a timely extension (Form 7004), the penalty may not apply — respond with proof

    3. 3

      Assess first-time abatement eligibility — three-year clean penalty history qualifies

    4. 4

      If FTA does not apply, document your reasonable cause for late filing

    5. 5

      Submit a written abatement request promptly — ideally before paying the penalty

    Resolution Options Available to You

    Frequently Asked Questions About IRS CP215

    How much is the CP215 penalty?

    The failure-to-file penalty is 5% of the unpaid tax per month (or part of a month), up to 25% maximum. If the return is more than 60 days late, the minimum penalty is the lesser of $485 or 100% of the unpaid tax (2024 amounts).

    Can I get CP215 abated if I paid the tax on time?

    The failure-to-file penalty is separate from the failure-to-pay penalty. Even if you paid the tax on time (by extension), a late return still triggers the failure-to-file penalty — but it may be reduced since the 'unpaid tax' used in the calculation is $0.

    What is the deadline to file Form 1120?

    C-corporation returns are due April 15 for calendar-year filers. A Form 7004 extension gives an additional 6 months (to October 15). The extension must be filed by the original due date.

    Does the IRS automatically grant first-time abatement?

    No — FTA must be requested. You can request it by phone or in writing. A written request creates a paper trail and gives you a basis for appeal if the first request is denied.

    Professional References

    IRC: IRC §6651 — Failure to File or Pay; IRC §6651(a)(1) — Failure to File Penalty

    IRM: IRM 20.1.2 — Failure to File/Failure to Pay Penalties

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    Last updated: September 7, 2026