Peter Procrastinator forgot to file his 20X3 tax return. Eventually thecollection 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 Deficiencyfrom 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