Edward W. Clough - Page 14

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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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