Publius Virgilius Maro never saw a SNOD, but his description of a famous monster fits pretty well. There is no form for a SNOD; all that IRS need communicate is that the Commissioner demonstrates that the IRS has determined that a deficiency exists for a particular year and specifies the amount of the deficiency. See my blogpost “Got Your Ticket?” 12/13/12.

The Com’r’s plaint is that Congressional defunding has caused his myrmidons to resort to form correspondence of the “one size fits all” variety.

Wherefore we are still getting orders of the sort we saw in my blogpost “Fake Out,” 12/16/14.

Here’s Kevin L. Williams, Docket No. 37192-21, filed 10/16/21, part of the Great Petition Tsunami from a year ago. Kevin got a LTR 96C, and petitioned. Ch J Kathleen (“TBS = The Big Shillelagh”) Kerrigan doesn’t enlighten us as to what the document might be, except it isn’t a SNOD.  True enough; a LTR 96C is what we used to call a DF, or Disposition Form, a species of buck slip whereby IRS asks for information, or states that it’s doing nothing, or announces electronically-calculated chops.

How exactly Kevin or anyone not a tax professional is to know this is not explained.

So Kevin is tossed.

I’m not faulting Ch J TBS or any of her colleagues; the law is what it is. Congress erected barriers around The Glasshouse on Second Street; IRS seems wedded to the ambiguity which they could eliminate, as they did by eliminating the whistleblowing epistolary volleying. Tax Court cannot rewrite the law, unlike its more august and exalted Article III types.

Taishoff says it’s time to echo the video mantra, Game Over.