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Hi and welcome to Just Answer!The notice that was signed by both an IL DOR agent and yourself may not be treated as a contract. They may review and assess additional tax liability within three years statute of limitation.If an assessment is correct - there is nothing you may do to resist it.You may however apply for Abatement of a Penalty based on a reasonable cause. If accepted - that will be some relief.Sorry if you expected a different answer. Let me know if you need any help.