Internal Revenue Manual 8.22.2.2.12.2 (10-30-2007)
Section 6702 Frivolous Return Penalties and Questionable W-4 Penalties
1. Frivolous Return Penalties and questionable W-4 penalties do not receive a notice that gives the taxpayer an opportunity to go to Appeals. Therefore, issues involving these penalties may be raised in CDP.
2. A taxpayer may challenge the assessment of the [...]

Internal Revenue Manual 11.3.13.1 (10-26-2007) Background
1. The Freedom of Information Act (FOIA) 5 USC 552, as amended by the 1974 Amendments to the Freedom of Information Act ( PL 93-502), the Freedom of Information Reform Act of 1986 (PL 99-570), and the Electronic Freedom of Information Act Amendments of 1996 (PL 104-231), provides for [...]