2. Alices brother, Edward, has come seeking your tax advice. He was self-employed in 2015. He did not make any estimated payments towards his 2015 income taxes. He filed for an extension on April 15, 2016, but he then never filed because he was in a car accident and spent months recovering. It is now 2017, and he is afraid to file because his return is so late.

a. If he were to file an accurate return tomorrow for 2015 that is prepared by a tax professional, what penalties can he expect the IRS to assert against him?

b. Will the IRS have to issue a Notice of Deficiency before assessing these penalties? c. Does Edward have any defenses he can raise against these penalties? d. What options does Edward have if he wants to challenge the assessment of the penalties by the IRS?