Which of the following taxpayers requires the services of an individual credentialed under Circular 230?

Marjorie had never filed her return or paid her taxes late until last year. She would like to request a first-time penalty abatement.

Carl and Jennifer received a collection notice and want to file an appeal.

David received a notice from the IRS and needs help interpreting and responding to it.

Sheila and Mary have a balance due they cannot pay in full and would like to enter into a payment agreement with the IRS.