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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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Last modified: November 10, 2007