1. Introduction: What is Form 14704?

IRS Form 14704, officially titled Transmittal Schedule – Form 5500-EZ Delinquent Filer Penalty Relief Program (Revenue Procedure 2015-32), is an administrative transmittal document published by the Internal Revenue Service (IRS). It is governed by Employee Plans (EP), a specialized branch within the IRS Tax Exempt and Government Entities (TE/GE) Division.

This form acts as a vital cover sheet and routing document for small business owners and self-employed professionals who sponsor one-participant retirement plans (commonly known as Solo 401(k)s, Individual 401(k)s, or owner-only pension plans) and failed to file their annual Form 5500-EZ. Attaching Form 14704 to a late filing package allows the plan sponsor to enter the permanent IRS penalty relief program, replacing potentially ruinous statutory late-filing fines with a modest, capped administrative fee.

2. Purpose of the Form: Why Does Form 14704 Exist?

Under federal tax law, small business owners who maintain a retirement plan covering only themselves, their spouse, or business partners must file an annual information return on Form 5500-EZ once plan assets exceed $250,000 at the end of the plan year (or upon plan termination). Because owner-only plans have no common-law employees, many entrepreneurs are unaware of this annual filing duty.

Missing this requirement triggers devastating penalties. Under Internal Revenue Code Section 6652(e) (as increased by the SECURE Act), the standard IRS penalty for a late Form 5500-EZ is $250 per day, up to a maximum of $150,000 per unfiled return, plus statutory interest. For small business owners missing several years of returns, these fines can easily exceed the entire value of their retirement savings. Form 14704 exists to solve this problem by:

Capping Catastrophic Fines: Under Revenue Procedure 2015-32, the IRS permanently caps late penalties at a flat $500 per delinquent return, with a maximum cap of $1,500 per submission, regardless of how many years are late.
Routing Late Submissions to the Relief Program: Form 14704 serves as the official routing slip that instructs IRS processing centers to grant penalty relief rather than issuing automated multi-thousand-dollar penalty notices.
Providing an Alternative to DOL Programs: The Department of Labor (DOL) manages a late-filer relief program for larger companies, but owner-only plans are exempt from ERISA Title I and cannot use the DOL system. Form 14704 provides a dedicated IRS-only solution.

3. Who Needs to File This Form?

Form 14704 is completed by business owners, self-employed professionals, and plan administrators who sponsor a non-ERISA retirement plan and missed one or more annual Form 5500-EZ filing deadlines. You should file this form if you meet the following criteria:

You sponsor a “one-participant plan” (such as a Solo 401(k), individual profit-sharing plan, or owner-only defined benefit plan) that covers only you, your spouse, or business partners and their spouses.
Total plan assets (cash and investments) exceeded $250,000 at the end of any prior plan year, or the plan was terminated, and you failed to file Form 5500-EZ by the statutory deadline (July 31 for calendar-year plans).
You have not yet received an IRS penalty notice (such as Notice CP 283 or CP 283-A) assessing a late-filing penalty for the delinquent year(s).
You sponsor certain foreign retirement plans subject to IRS annual reporting under Section 6048.

4. Who Is Exempt / Not Required to File?

Not every retirement plan sponsor needs Form 14704. You are exempt or not eligible to use this relief transmittal under the following circumstances:

Plans with Assets Under $250,000: If the total balance of your one-participant plan remained at or below $250,000 at the end of the plan year, you are legally exempt from filing Form 5500-EZ altogether (unless it was the final year of a terminated plan).
ERISA Plans with Common-Law Employees: If your company retirement plan covers regular, non-owner employees, it is subject to Title I of ERISA. You cannot file Form 5500-EZ or Form 14704; you must file Form 5500 and seek relief through the Department of Labor’s Delinquent Filer Voluntary Compliance Program (DFVCP).
Sponsors Who Already Received Notice CP 283: If the IRS has already mailed you a formal penalty assessment notice (Notice CP 283) for a specific delinquent year, that year is disqualified from Rev. Proc. 2015-32 relief. You must seek penalty abatement by submitting a reasonable cause statement instead.
Compliant Plans: Business owners who have consistently filed Form 5500-EZ on time each year have no reason to use this form.

5. When to File: Deadlines and Frequency

Form 14704 is an event-based, one-time transmittal schedule rather than an annual recurring filing. You prepare and submit it as soon as you discover that past-due Form 5500-EZ returns were missed.

Timing is critical. You must submit Form 14704 and your delinquent returns before the IRS detects your non-filing and mails an official CP 283 penalty notice. Once the IRS issues that notice, the door to the $500-per-return relief program closes permanently for that tax year. Multiple delinquent years for the same retirement plan can be grouped together into a single Form 14704 submission.

6. Where and How to File

Filing under the Form 5500-EZ Delinquent Filer Penalty Relief Program requires strict adherence to physical paper filing rules. Electronic filings do not qualify for penalty relief:

Paper Filing Only: You cannot e-file through the Department of Labor’s EFAST2 system or commercial tax software. Delinquent returns must be prepared on paper using the official Form 5500-EZ for each specific delinquent year.
Attachment Order: Form 14704 must be placed as the top cover page, physically attached to the front of the oldest delinquent return in your submission package.
Required Return Marking: For each delinquent Form 5500-EZ, you must check Box D (for the IRS Late Filer Penalty Relief Program) in Part I. If using an older version of Form 5500-EZ that lacks Box D, you must write in red ink at the top of the first page: “Delinquent Return Filed under Rev. Proc. 2015-32, Eligible for Penalty Relief.”
Mailing Address: Mail the complete package—including Form 14704, all delinquent returns, and your payment check—via certified mail to the designated IRS address as per instructions for Revenue Procedure 2015-32 (the IRS Submission Processing Center in Ogden, Utah).

7. Step-by-Step Instructions to Fill Form 14704

Form 14704 is a straightforward, single-page transmittal schedule. Because it routes your payment and validates your eligibility, every line must be filled out accurately. The table below outlines each line item on the form.

Line Item	Item Title	Information Required
Line 1	Applicant’s Name	Legal name of the plan sponsor (business name or sole proprietor name) or plan administrator.
Lines 2 & 3	Applicant’s Address	Physical street address, city, state, ZIP code, or foreign country details.
Line 4	Applicant’s EIN	Nine-digit Employer Identification Number (do NOT enter a Social Security Number).
Line 5	Telephone Number	Daytime telephone number of the plan sponsor or authorized representative.
Line 6	Plan Number	Three-digit retirement plan sequence number (e.g., 001, 002).
Line 7	Plan Name	Exact formal legal name of the retirement plan as written in your plan document.
Line 8	Plan Year Ending Dates	The last day (MM/DD/YY) of each plan year for every delinquent return included.
Line 9	Amount of Payment	Checkbox selecting $500 (1 return), $1,000 (2 returns), or $1,500 (3 or more returns).

Lines 1 through 3: Plan Sponsor Information

Enter the legal name of the business entity or sole proprietorship that sponsors the retirement plan. Provide the current mailing address where the IRS can send written correspondence. If the plan sponsor is a partnership or corporation, enter the entity’s registered business name.

Lines 4 and 5: Employer Identification Number (EIN) and Phone

Enter the plan sponsor’s nine-digit Employer Identification Number (EIN). Never enter a Social Security Number (SSN) on Line 4. Even if you operate as a sole proprietorship, retirement plans must be associated with an EIN. If you do not have an EIN for your business or plan, you must obtain one before filing Form 14704.

Lines 6 and 7: Plan Number and Plan Name

Enter the three-digit plan number assigned to the retirement plan (typically 001 for a business’s first retirement plan). Enter the exact formal name of the retirement plan (for example, “Acme Consulting Solo 401(k) Plan”) exactly as it appears in your original plan adoption agreement.

Line 8: Delinquent Plan Year Ending Dates

Enter the last day (month, day, and year) for every delinquent plan year included in your submission. For example, if you are submitting late returns for calendar years 2021, 2022, and 2023, you would enter 12/31/21, 12/31/22, and 12/31/23. Ensure these dates match the plan year dates on the attached Forms 5500-EZ.

Line 9: Payment Calculation

Select the applicable fee checkbox based on the number of delinquent returns for this specific plan included in your packet:

(a) One delinquent return: $500 fee.
(b) Two delinquent returns: $1,000 fee.
(c) Three or more delinquent returns: $1,500 fee (the fee is permanently capped at $1,500, regardless of whether you are filing 3, 5, or 10 late years for the same plan).

Attach a check or money order made payable to the “United States Treasury” for the exact amount. Write the plan sponsor’s EIN, the plan number, and “Rev. Proc. 2015-32” in the check memo line.

8. Required Documents and Information Needed Before Filling

Before assembling your penalty relief submission package, compile the following financial and plan records:

The original executed retirement plan document, adoption agreement, and trust agreement to verify the legal plan name, EIN, and plan number.
Paper copies of the official Form 5500-EZ for each delinquent year (or current-year forms adapted with corrected year dates for pre-1990 filings).
End-of-year brokerage, bank, and custodial account statements for each delinquent year showing total plan assets, liabilities, and contributions.
A check or money order for the exact fee ($500, $1,000, or $1,500) payable to the “United States Treasury.”
A signed Form 2848 (Power of Attorney) if a CPA, enrolled agent, or ERISA attorney is preparing and signing the submission on your behalf.

9. Common Mistakes to Avoid

Failing to follow the strict procedural rules of Revenue Procedure 2015-32 can result in your submission being rejected, exposing you to full statutory penalties. Avoid these frequent errors:

E-Filing Through EFAST2: The IRS penalty relief program strictly requires paper filing. Electronically filed delinquent returns submitted via EFAST2 are automatically disqualified from the $500 fee cap and will trigger standard $250/day penalties.
Entering a Social Security Number on Line 4: Entering an individual SSN instead of an entity EIN will cause processing errors and delays. Always use an EIN.
Combining Multiple Plans on One Form 14704: If you operate two separate retirement plans (such as a Solo 401(k) and a separate Defined Benefit plan), you must prepare separate Form 14704 packages and pay separate fees for each plan.
Filing After Receiving a CP 283 Notice: You cannot use Form 14704 for any tax year for which the IRS has already mailed a CP 283 penalty notice. Submitting Form 14704 for an audited year will result in your check being cashed without penalty relief.
Omitting the Red-Ink Marking or Box D: If you fail to check Box D on Part I of Form 5500-EZ (or write the required red-ink notation on older forms), IRS mail clerks may process your returns as standard late filings and issue statutory penalty notices.
Forgetting Original Signatures: Every delinquent Form 5500-EZ must be signed and dated in ink by the plan sponsor or administrator. Unsigned returns are rejected.

10. Penalties for Non-Filing or Errors

The contrast between the penalty relief program and standard statutory IRS penalties is staggering:

Standard Penalties (Without Form 14704): Under Internal Revenue Code Section 6652(e), the IRS assesses a late penalty of $250 per day, up to a maximum of $150,000 per unfiled return, plus compounded interest. Additionally, late actuarial reports for defined benefit plans incur a $1,000 penalty under Section 6692.
Relief Program Terms (With Form 14704): Under Revenue Procedure 2015-32, your maximum liability is capped at $500 for one year, $1,000 for two years, or a flat $1,500 for three or more years. All standard Section 6652(e) and Section 6692 penalties are completely waived.
Rejection Risks: If your Form 14704 packet is rejected due to an incorrect payment amount, missing signatures, or prior CP 283 notices, the IRS can immediately assess the full $150,000 penalty.

11. Related Forms or Schedules

Form 14704 operates within a specialized collection of retirement plan compliance and annual reporting documents:

Form 5500-EZ: Annual Return of A One-Participant (Owners/Partners and Their Spouses) Retirement Plan (the return being transmitted).
Form 5500 / Form 5500-SF: Annual Return/Report of Employee Benefit Plan (used for plans covering non-owner employees).
Form 5558: Application for Extension of Time to File Certain Employee Plan Returns.
Notice CP 283 / CP 283-A: Penalty Notice for Late Filing of Form 5500-EZ.
Form 2848: Power of Attorney and Declaration of Representative.
Form SS-4: Application for Employer Identification Number.

12. Frequently Asked Questions (FAQs)

1. Can I e-file my delinquent Form 5500-EZ returns and still use Form 14704?

No. Under IRS Revenue Procedure 2015-32, delinquent returns submitted electronically via EFAST2 are strictly ineligible for penalty relief. You must file paper copies through the mail with Form 14704 attached.

2. What if I missed five years of Form 5500-EZ filings for my Solo 401(k)?

You can catch up on all five years in a single submission. You will prepare five paper Form 5500-EZ returns, attach Form 14704 to the front of the oldest return, check the “$1,500” box on Line 9, and include a single check for $1,500. Your total penalty is capped at $1,500 rather than $750,000.

3. What should I do if I already received an IRS CP 283 penalty notice?

If you already received a CP 283 notice, you are disqualified from using Form 14704 for that year. You must respond directly to the notice by submitting a written request for penalty abatement based on “reasonable cause” (such as serious illness, natural disaster, or third-party record destruction).

4. Does the IRS send a confirmation letter after accepting Form 14704?

The IRS generally does not issue formal acceptance or closing letters under this program. Your proof of acceptance is your cashed payment check and the certified mail return receipt confirming delivery to the IRS Ogden processing center.

5. Can I use Form 14704 if my Solo 401(k) had less than $250,000 in assets?

If your plan assets were $250,000 or less at the end of each plan year, you were never legally required to file Form 5500-EZ, so no penalties apply. However, if the plan terminated, you must file a final return regardless of asset value, and Form 14704 can be used if that final return was late.

6. Can I submit Form 14704 for two different businesses together?

No. Form 14704 applies strictly to one plan sponsored by one employer. If you own two separate businesses that each have a delinquent Solo 401(k) plan, you must submit two separate packages with separate Forms 14704 and separate fee payments.

13. Conclusion: Key Takeaways

IRS Form 14704 is one of the most generous penalty relief mechanisms in the entire Internal Revenue Code. For self-employed individuals and small business owners with delinquent Solo 401(k) filings, submitting Form 14704 under Revenue Procedure 2015-32 replaces potential $150,000-per-year late penalties with a modest, capped administrative fee.

Because the relief program requires exact adherence to paper filing guidelines, red-ink markings, and fee structures—and becomes unavailable the moment the IRS issues a penalty letter—plan sponsors should assemble their past-due returns, complete Form 14704, and mail their submission via certified mail immediately upon discovering a missed filing.

IRS Form 14704 Guide: Solo 401(k) 5500-EZ Penalty Relief