28. A Statutory Notice of Deficiency may be rescinded under Code Section 6212(d) with the consent of the taxpayer if:

o The taxpayer specifically requests such rescission within the 90 day period.

o The taxpayer submits information establishing that he has good cause to believe that the actual tax liability is less than that shown in the Notice of Deficiency.

o The taxpayer agrees to execute a Form 872.

o The Notice was issued as the result of an administrative error.