Eventually collection function of IRS contacted

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Question

Peter Procrastinator forgot to file his 20X3 tax return. Eventually the collection function of the IRS contacted him and, after several delays, Peter was able to file a tax return early in 20X6. The return showed aliability in tax of $5,500, which Peter tendered along with the return.Peter also sent a second check to pay all of the interest due to date. Approximately two months later, Peter received a Notice of Deficiency from the Service Center. The Notice showed an assessment of tax of$5,500, interest in the approximate amount that Peter had computed, anddelinquency and substantial understatement penalties. Peter wishes tochallenge the assessment of the penalties. What are his chances?

Reference no: EM134014728

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