|A creative image of the IRS Notices Section, where 90-Day Letters are prepared.|
 See IRS Letter 5262 (8-2014); catalog number 65056U
 The 90-Day Letter is also sometimes referred to as The Notice, The SND, the Stat Notice, or the Statutory Notice of Deficiency.
 An unagreed case is where an audit results in the taxpayer not agreeing with the agent’s proposed adjustments. An agreed case is where the taxpayer and the IRS agree to proposed adjustments as compromised or proposed by the agent. A “no change” case is one in which the IRS agrees fully with the return as filed.
 A case is in “docketed status” when a taxpayer timely files a Petition in the U.S. Tax Court. A case is in “calendared” status once the case is listed on a trial calendar upon the issuance of a Notice Setting Case for Trial in the Tax Court.
 Appeals Officer
 An assessment of tax is a term of art meaning an actual entry of the liability on the “books” of the IRS. The numbers set forth in the 90-Day Letter simply means the IRS is saying, “you better start paying attention to this because we are getting ready to jump all over you with both feet. “
 After 30 years with the IRS I am convinced that “Notices” is a black hole in space somewhere where files disappear forever or sometime come out the other end after a 90-Day Letter is issued to the taxpayer who thought all along that the IRS lost interest in the case or lost the file.