So, you send in a written response with evidence that completely clears up the case but it takes the IRS so long to get to it an NOD is generated, what then?  I have a notice 6 months after the original CP2000 that an NOD had been issued (taxpayer has not seen one) so they can't abide by the amended return that was filed before the due date of the original CP2000 notice.  It is cr-p like this that just ends up being tremendous time eaters.