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limitations period. Petitioner also argues that the Forms W-2
filed by her employers satisfied her filing requirement for the
years at issue. She did not otherwise address the determination
that she failed to pay estimated taxes.
1. The Notices of Deficiency Satisfied All Requirements
Each of the notices of deficiency in these cases
unambiguously identifies both the amounts of the deficiencies and
the years involved. Each statutory notice tells the taxpayer all
that is required.3 See Foster v. Commissioner, 80 T.C. 34, 229-
230 (1983), affd. in part and vacated in part 756 F.2d 1430 (9th
Cir. 1985); Jarvis v. Commissioner, 78 T.C. 646, 655-656 (1982).
Except in rare circumstances, this Court will not look behind a
notice of deficiency to examine the administrative proceedings or
the propriety of respondent's motives leading to the deficiency
determination. Berkery v. Commissioner, 91 T.C. 179, 186-187
(1988), affd. without published opinion 872 F.2d 411 (3d Cir.
1989); Vallone v. Commissioner, 88 T.C. 794, 806 (1987).
Exceptions to this general rule have been recognized where there
has been substantial evidence of unconstitutional conduct by
3 Each notice contains a description that satisfies sec. 7522,
which provides for the general content of tax due, deficiency,
and other notices. We note that this provision was originally
enacted as sec. 7521(2) by sec. 6233(a) of the Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat.
3342, 3735, applicable to mailings made on or after January 1,
1990, and was redesignated as sec. 7522 by sec. 11704(a)(3) of
the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508,
104 Stat. 1388, 1388-519.
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