I most respectfully request Judge Elizabeth A. (“Tex”) Copeland to call a statutory notice of deficiency a SNOD, to distinguish it from a notice of determination, known as a NOD (as, e.g., in a CDP, whistleblower, worker classification, 501(c)(3) or retirement plan disqualification case).

The designated hitter William Michael Shumer & Susan Elaine Shumer, Docket No. 9095-19, filed 3/13/20, was clear enough on the law (no need for a signature on a SNOD), but confusing in nomenclature.