Assessable chops (those that do not require a prerequisite SNOD) entitle the recipient to contest liability in a CDP when IRS attempts to collect the tax underlying the chop. This arises most often in the context of Section 6702 frivolous returns.

Araya AnRa, Docket No. 6805-22SL, filed 2/17/23, gives Judge Nega the opportunity to declare “no contest,” in an off-the-bencher.

Araya gets a bunch Section 6702 chops for three (count ’em, three) years of zero-returns and Section 4852 restatements. At the trial, she claims the usual protester “hodgepodge of unsupported assertions, irrelevant platitudes, and legalistic gibberish.” Transcript, at p. 15.

No contest of liability unless a legitimate issue of fact or law is raised. Araya only raises the employment taxes mishmash about “wages” that has been denounced as frivolous for yeasrs. And Judge Nega spares us most of the somber reasoning and copious citation of precedent.