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deduction on the income tax return. Since respondent has
disallowed, in the notice of deficiency, expenses of $658,000,
petitioner contends that respondent, in effect, has disallowed
$151,382 of expenses that are not related to petitioner's merger
activity. Petitioner further argues that, given that petitioner
informed the IRS agent that petitioner did not in fact incur
merger-related expenses of $151,382, and respondent, nonetheless,
disallowed such expenses in the notice of deficiency, respondent
should be required to advise petitioner what items of expenses on
petitioner's tax return comprise the $151,382 disallowed
expenses. Because respondent, in the audit process, failed to
provide such information, petitioner contends that respondent
failed to make a "determination" of a deficiency attributable to
the $151,382, and, therefore, this Court lacks jurisdiction as to
this $151,382 portion of the $658,000 adjustment. To quote from
petitioner's memorandum of authorities, "Petitioner repeatedly
requested more specificity as to which expense(s) was being
reviewed to permit identification and retrieval of all source
documentation and other potential support. Respondent refused to
be more specific as to which expense(s) was being reviewed."
When the examining agent later proposed to disallow the $658,000,
petitioner responded in writing that the $151,382 (of the
$658,000) "was a plug and not identifiable as legal or
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