In First American Commercial Real Estate Services, Inc. v. County of San Diego (2011) 196 Cal.App.4th 218, the plaintiff, which provided tax services to lenders and was responsible for making payments of property taxes on behalf of property owners, sent approximately $60 million in payments by 13 wire transfers. (First American, supra, 196 Cal.App.4th at pp. 221-222.) It failed to timely send approximately $6 million on behalf of Bank of America, "because of an internal error in formatting a spreadsheet used in making the wire transfers," which resulted in the amount intended to be transferred for Bank of America being hidden, so the payment was overlooked. (Id. at p. 222.) The plaintiff sent the omitted payment one day late, and the tax collector charged a 10 percent penalty. (Ibid.) The plaintiff sought cancellation of the penalty pursuant to section 4985.2, subdivision (a). (First American, supra, at p. 222.) The court concluded the clerical error did not constitute circumstances beyond the plaintiff's control. (First American, supra, 196 Cal.App.4th at pp. 225-226.) It noted the plaintiff's error in formatting the spreadsheet was very similar to the error in ZC Real Estate. "Both are clerical errors that were plainly inadvertent, but which were within the parties' control and avoidable. In this case, the payment would have been timely if First American would have acted differently in formatting its spreadsheet, in designing its processes for initiating wire transfers or in taking additional steps to confirm wire transfers before the payment deadline." (First American, supra, at p. 227.) The court rejected the plaintiff's contention circumstances beyond the taxpayer's control should be found in any situation in which the taxpayer exercised ordinary care and avoided willful neglect, because that interpretation would effectively eliminate from the statute the requirement that the circumstances causing the delinquency be beyond the taxpayer's control. (Id. at pp. 227, 230.) Because the inadvertent clerical error that caused the late payment was not beyond the plaintiff's control, despite the exercise of ordinary care, the statutory requirements for cancellation of the late penalty were not met. (Id. at p. 226.)