Here is my question - since only 2019 was required, would we only file 2019 under the DFVCP and pay the $500 and leave well enough alone? I'm hesitant to file 2018 and 2020. I don't want to send up a flag for a return that, A) wasn't required, and B) wasn't filed. Maybe, will the IRS accept the unnecessary returns if filed late and not under the DFVCP and say "ok, thanks, you didn't need to file but you did", or do you think if I am filing late regardless of had to or not, I still need to file with a $500 IRS user fee? File all 3 late with $1500 fee under the DFVCP program?