I have a client who filed late for a number of years, beginning with 2002 and 2003 and continuing on to 2007. After looking at all of her information, it appears that everything would be dischargeable except 2006 and 2007. However, when I was looking at her statement of account, it does show that the IRS issued SFRs for 2002 and 2003 at the same time (12/05). The actual return transcript (which is for the SFR) is all zeroed out except for the line items for the personal exemption. After reviewing the account transcripts for those years, the IRS issued the SFR, then sent my client a notice that if she didn’t file, the IRS would determine her tax liability. After receiving that notice, she did file and the tax liability she came up with is listed as “additional liability assessed.” From everything I’ve seen, there was never a formal initial assessment, although I guess you could argue that since the SFR was filed, the initial assessment was $0.00.