- 3 - by law. On August 6, 2002, petitioner submitted a Form 656, Offer in Compromise, to respondent based on doubt as to liability in which petitioner offered to pay the deficiencies but not any penalties or statutory interest. On September 18, 2003, respondent sent petitioner a letter rejecting the offer. On February 6, 2005, petitioner submitted a Form 843, Claim for Refund and Request for Abatement (request), with respect to the section 6662(a) penalties and the accrued interest. On August 31, 2005, respondent sent a letter to petitioner stating that respondent would not review the portion of the request relating to the abatement of the assessed penalties. On October 17, 2005, respondent sent petitioner a 30-day letter stating that petitioner’s request had been denied on the grounds that “There was no unreasonable error or delay relating to the performance of a ministerial or managerial act in processing the examination of your return.” Petitioner did not respond to the 30-day letter. On a date that cannot be ascertained precisely from the record, but which the parties allege was either December 1 or December 5, 2005, respondent issued a notice of final determination denying petitioner’s request under section 6404(e)(1). On February 13, 2006, petitioner timely filed a petitionPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007