In some cases, taxpayers may even request a reduction in the penalty due to a lack of knowledge of the law. Relevant factors include education, whether the taxpayer has been subject to the tax before, whether the taxpayer has been penalized before, the complexity of the tax issue, and recent changes in the law or tax forms. How about forgetfulness as a basis for reasonable cause? The IRS says that forgetfulness indicates a lack of reasonable cause. Reasonable cause is based on all the facts and circumstances of your situation.
The IRS will consider any reason that shows that you used all the usual business care and prudence to meet your federal tax obligations, but were nonetheless unable to do so. Reasonable cause is any legitimate excuse for not paying or filing the request on time. The problem must be beyond your control. In addition, you must prove to the IRS that you tried to file the application, but that it was basically impossible.