Statutory Notice of Deficiency (SNOD)

A notice of deficiency, also called a "statutory notice of deficiency" or "stat notice," is the IRS's determination of a taxpayer's income, excise, employment, estate or gift tax deficiency sent to the taxpayer by certified or registered mail.

IRC 6212(a) and 26 CFR 301.6212-1 authorize the IRS to send this notice.

Mandatory Review or Technical prepares and issues all Statutory Notices of Deficiency and Notice of Employment Tax Determination Under IRC 7436.

A SNOD is the Commissioner’s, as a delegate of the Secretary, legal determination of the taxpayer’s tax liability.

Functional Directors and Area Managers are authorized to sign a SNOD, on the Commissioner’s behalf.

A taxpayer must file a Tax Court petition within 90 days (150 days if the SNOD is addressed to a taxpayer outside the United States) after the IRS mails the SNOD. All references in this IRM to the 90-Day Letter include the 150-Day Letter, when applicable.