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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.
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