I filed a certain year (and several others) after the 2 year requirement from date of payment for a substitute for return (4 years in total after the payment).

Now I understand the law barring refunds after 2 years, however, I filed an appeal due to:

My accountant whom I paid made a huge error on the year in question and made the amount due more than 16x the actual amount due. This error dissuaded me from filing a few years in a row, including the one in question, because of such a high erroneous amount due. I have proof of this (accountants forms/signature). As soon as I found out, I filed all returns promptly.

This was not the only issue which made me file late, there are a few other reasons like lack of financial resources to actually pay anyone else to help me further with regards to prior years and other hardships.

But ultimately, this error was the main, almost sole reason for not filing. Couple the fact that all my years had complicated carry forwards as well and it was almost impossible to file other years without filing this year with the error.

Basically, isn't there some sort of exception, hardship or reasonable procedures in place when you pay an accountant a lot of money, he screws up, and it mucks up so many years in a row, that there is reasonable cause to excuse a late filing?

Any insight?