I have found a issue with the ATO internal systems allowing a simple path for some objections to penalties being imposed. This then flows through to SIC as a consequence. I don't want to publically share it but happy if any taxpayer is smacked with a penalty decision to explain the issue. Important and key issue for anyone EXPECTING a penalty is to have a tax agent with access to the Tax Agent Portal to assist proving the issue. Any tax advisers wanting to know the issue direct email me. No ATO enquiries please.