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We had almost the identical problem you mention several years ago. The Memphis office accepted our appeal, but the Philadelphia Office did not (why two different offices got involved is a mystery). So Remember there is the Taxpayer Advocate Service that can help you. If you run into a problem, make a copy of everything and go see the Advocates Service. If they take the case, you probably have no more worries as things are stopped dead. Our case was resolved in two steps: the first was to rescind the penalty (which is huge) and interest and the second was to drop the case so we ended up all right but it took about 7 mo.

brucedoe
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