- 14 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007