<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Friday, September 9, 2016 10:38 PM</td></tr><tr><td>To:</td><td>Fenn, Patrick</td></tr><tr><td>Subject:</td><td>other things we might consdider including</td></tr></table>

- The taxpayer's education;

- Whether the taxpayer has previously been subject to the tax for which =he return has not been filed;

- Whether the taxpayer has be=n penalized before;

- The level of complexity of a tax or c=mpliance issue.

T

The tax=ayer complied with tax filing and payment obligations in the past- =AO

r=cently told and then he immediatly filed his previously unfiled retu=ns;

=here was no indication that he had taken efforts to intentionally conceal =he reporting of income or assets; no tax difference. no =vasion,

In making the reasonable cause argument, it is critically important to analyze the facts, support the facts with affidavits or other evidence.. these are all questions , should w= attachh affatdavits from preparer, apollo others.=et.c

please note<=r>

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