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the documents that were requested For 2000: these are not the
SNOD. Requested DLN of the TC 290. Checked ICS: no ICS history
for this t/p.”9 The activity record also shows that the hearing
officer made the following entry on July 20, 2005: “To date I
have been unable to verify a SNOD for 2000. For 1996-1998
liability issues are precluded from consideration. For 2000 they
may not be, but the t/p has not brought up any relevant
arguments, just frivolous arguments.”
The relevant parts of the record summarized above establish
that the hearing officer did not receive verification during
petitioner’s section 6330 hearing that respondent had issued a
notice of deficiency for 2000 to petitioner before assessing
petitioner’s 2000 deficiency. Moreover, the record contains no
indication that the hearing officer or the Appeals Office
considered the effect on the 2000 assessment of a failure by
respondent to verify that a notice of deficiency for 2000 was
mailed to petitioner.
9Although the entries in the activity record are not always
intelligible due to the coding and numbering utilized by
respondent’s employees, we understand the term “SNOD” to be an
acronym for a statutory notice of deficiency.
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Last modified: November 10, 2007