Once again Judge Tamara W. Ashford whistles IRS’ play dead, as demanding a remand to Appeals because IRS is “unsure of the appropriate way to proceed with collection” in Jevon Kearse, Docket No. 14080-14L, filed 8/9/19, (order, at p. 1) doesn’t get it when IRS can find neither USPS Form 3877 or IRS equivalent signed off by a USPS employee to prove they sent Jevon the SNOD.

No remand when IRS blew the statutory requirement for verification of all necessary steps, stipulates that they can’t provide necessary items, and hopes for remand to bail them out.

So once again “The Freak” triumphs. For the backstory, see my blogpost ”Sacked,” 5/20/19.

And I’m gratified to see Judge Ashford has adopted the Taishoff Convention: a SNOD is a Statutory Notice of Deficiency, to distinguish it from a NOD, Notice of Determination. Order, at p. 3, footnote 4.