SECTION 4. ELIGIBILITY

.01 A request for reduction must comply with the requirements of this section. A person whose request does not comply with these requirements will not be eligible for a reduction of a section 6702 penalty.

(1) Form of request . A person must make a written request for reduction on IRS Form 14402, “ IRC 6702(d) Frivolous Tax Submissions Penalty Reduction,” (or successor form) or as prescribed by the Form’s instructions. The person must also sign the form or written statement under penalties of perjury, and file it with the IRS in accordance with instructions to the form or other guidance. A person may file a single Form 14402 or written statement to

26 C.F.R. 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability.

Rev. Proc. 2012–43