OPINION
SILVERMAN, Circuit Judge:
The district court held that the taxpayer's administrative claim failed to give the IRS adequate notice of one of the bases for its claim of entitlement to abatement of late-payment penalties. We disagree, and hold that the taxpayer's claim was, indeed, sufficient to put the IRS on notice of the nature of the claim. We reverse that portion of the ruling.
The district court also held that the taxpayer failed to establish...
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