refers to removal of penalties or interest liability. This generally can be obtained only if the taxpayer can show that the penalty event was due to reasonable cause and not willful neglect. Reasonable cause is a factual determination. Criteria for determining reasonable cause include (but are not limited to): death or serious illness of taxpayer or immediate family; unavoidable absence of taxpayer; destruction of records by fire and inability to obtain necessary records. Abatement of interest is available only in quite limited circumstances.