- 15 - After reviewing appellant's 1981 notice of deficiency, we conclude that it was sufficient to establish jurisdiction. The notice clearly indicates that appellants' PCS, Ltd., pass-through deduction of $12,500 was being disallowed, that their tax was being recomputed, and that a negligence penalty was being imposed. There is neither blatant error nor any statement which would suggest that the Commissioner had not made a determination using appellants' tax return. Kantor v. Commissioner, supra at 1521-1522. Applying the principles discussed in Kantor v. Commissioner, and by this Court in Campbell v. Commissioner, supra, to the notice of deficiency issued to petitioner in the present case, we are not convinced, as petitioner contends, that respondent failed to make the requisite determination. There is no dispute that the notice of deficiency relates to the decedent's estate and that respondent correctly listed the decedent's social security number. It is also evident that respondent's determination of a deficiency in petitioner's Federal estate tax derived from a review of both the estate tax and gift tax returns filed on behalf of both petitioner and the Estate of James R. Rickman. Specifically, we need go no further than to point out that the valuation adjustments in respect of the 6 parcels of real estate set forth in the notice of deficiency directly coincide with real estate reported on petitioner's estate tax return. In sum, the evidence is irrefutable that respondent examined petitioner's estate tax return.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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