Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 15

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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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