ACCORDING TO IRM 20.1.1.3.2, REASONABLE CAUSE, THE IRS PROVIDES RELIEF FROM A PENALTY BASED ON REASONABLE CAUSE WHEN THE TAXPAYER EXERCISED ORDINARY BUSINESS CARE AND PRUDENCE IN DETERMINING HIS OR HER TAX OBLIGATIONS BUT WAS NEVERTHELESS UNABLE TO COMPLY WITH THOSE OBLIGATIONS.THE ANTICA FOUNDATION (THE "FOUNDATION") WAS INCORPORATED ON NOVEMBER 25, 2019. IN MARCH OF 2020, THE FOUNDATION AND ITS OFFICERS AND DIRECTORS FACED THE WORLDWIDE THREAT OF THE COVID-19 PANDEMIC, WHICH IMPACTED ALL ASPECTS OF LIFE AND CREATED MANY UNCERTAINTIES AND CHALLENGES. AS THE FOUNDATION WAS JUST GETTING STARTED AND FORMULATING ITS BEARINGS, THE COVID-19 PANDEMIC CREATED AN UNEXPECTED AND BURDENSOME SET BACK TO THE OPERATIONS AND THE PLANS OF THE FOUNDATION. THE DELAY TO FOUNDATION MATTERS, INCLUDING ITS UNDERSTANDING OF AND COMPLIANCE WITH TAX REPORTING OBLIGATIONS, WAS CAUSED BY OFFICE SHUTDOWNS, STAFFING ISSUES RELATED TO HEALTH, WELLBEING AND FAMILY RESPONSIBILITIES. MOREOVER, THE TAX REPORTING OBLIGATIONS OF EXEMPT ORGANIZATIONS IS AN EVOLVING AND TECHNICAL AREA OF TAX LAW. THE FOUNDATION, AS A NEW ENTITY, WAS NOT FAMILIAR WITH SUCH REPORTING REQUIREMENTS.AS THE CONDITIONS OF THE COVID-19 PANDEMIC IMPROVED AND THE FOUNDATION WAS ABLE TO RE-ESTABLISH ITS ACTIVITIES, THE FOUNDATION DISCOVERED OF THE OBLIGATIONS TO FILE THE FORM 990-PF. THE FOUNDATION TOOK IMMEDIATE ACTION TO CONSULT WITH TAX PROFESSIONALS TO RECTIFY THE FAILURE TO FILE. ALTHOUGH THE FOUNDATION EXERCISED ORDINARY BUSINESS CARE AND PRUDENCE AND MADE A GOOD-FAITH EFFORT TO MEET ITS TAX DEADLINES, THEY WERE UNABLE TO DO SO DUE TO COVID-19 IMPACTS. GIVEN THESE FACTS, THE FOUNDATION RESPECTFULLY REQUESTS THAT YOU FIND THE FOUNDATION'S FAILURE TO FILE ITS FORM 990-PF WAS DUE TO REASONABLE CAUSE.