Tan Xuan Bui - Page 3




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          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 petition               







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