Clint and Claudia Collins are a married couple who filed a joint return for the 2023 tax year. The Collins were out of the country on the due date for filing their 2022 tax return, so they asked their CPA to file an extension. The CPA properly completed the extension form and queued it up to file electronically with her software. Unfortunately, the CPA never hit the submit button and did not realize the error until October 15 when she wanted to electronically file the tax return at the extension due date. As a result, the Collins’ tax return was not timely filed, and the IRS assessed a late filing penalty of $83,650 against the Collins. The couple paid the penalty and have filed a case in their District Court to have the penalty abated. The Collins state that they relied on their CPA to properly file the extension and they should not be assessed the penalty. Conduct research to determine if the Collins have reasonable cause to have the penalty abated.