Determination of deficiency, penalty, or interest

Upon receipt of a notice of deficiency or assessment of penalty or interest under sections 3202 and 3203 of this title, the taxpayer may, within 60 days after the date of the notice or assessment, petition the Commissioner in writing for a determination of that deficiency or assessment.
The Commissioner shall thereafter grant a hearing upon the matter and notify the taxpayer in writing of his or her determination concerning the deficiency, penalty, or interest. (