The IRS currently charges a $195 per partner per month fee on the late filing of partnership returns. Eliminating this burden for all returns marked initial return and instead educating first year filers of the late penalty requirements would go a long way in building relationships between small business and the IRS.
A 2 individual partnership filing 6 months late, incurs a fine of $2,340, this could be an entire months rent or payroll for a small business. The amount is entirely arbitrary as any tax on the partners will be imposed at the individual return level and assuming the individual filed timely with proper extensions it represents an unjust taking by the IRS without reasonable notice to small business owners and entrepreneurs.