Waive underpayment penalty on repayment of excess 2023 Premium Tax Credit?

I received advance payments of the ACA Premium Tax Credit in 2023, but the amount advanced exceeds the amount I can actually take. Repayment of the excess credit is triggering an underpayment penalty (otherwise I would not have a penalty).

 

Can I request a waiver of this penalty? TurboTax indicates I can do so but provides little assistance doing so.

Is this old rule from 2014, https://www.irs.gov/pub/irs-drop/n-15-09.pdf , still in effect?

 

PENALTY RELIEF RELATED TO ADVANCE PAYMENTS OF THE PREMIUM TAX CREDIT FOR 2014 Notice 2015-9 Purpose This Notice provides limited relief for taxpayers who have a balance due on their 2014 income tax return as a result of reconciling advance payments of the premium tax credit against the premium tax credit allowed on the tax return. Specifically, this Notice provides relief from the penalty under § 6651(a)(2) of the Internal Revenue Code for late payment of a balance due and the penalty under § 6654(a) for underpayment of estimated tax. To qualify for the relief, taxpayers must meet certain requirements described below. This relief applies only for the 2014 taxable year.