Jim, while TC petition does not need to provide substantiation, I trust that you have substantiation to support statement that SE expenses were ignored. Does TP have sufficient evidence to support SE deductions? I would have thought that this substantiation would have been provided at the CDP hearing. If those deductions were not accepted at the CDP hearing, you need to understand why. To simply resubmit the same proof of expenses that were previously denied will likely result in the same result. With respect to Chai defense for penalty assessment, it is my understanding that not all penalties need written managerial approval. I believe AUR generated CP 2000 notices do not need managerial approval as these are computed generated. If total assessment, including penalties is $10K, did you attempt to have penalties abated at CDP hearing by agreeing to tax assessment. Also, did you check transcripts to see if TP is eligible for FTA?