Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 16

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          Petitioner contends that respondent failed to make a                        
          determination as required under section 6212(a) on the grounds:             
          (1) The adjustment described in paragraph (a) of the explanation            
          of adjustments was not adequately supported due to respondent's             
          failure to attach exhibits A and B referred to therein to the               
          notice of deficiency; (2) the valuation adjustments in respect of           
          the real estate listed on petitioner's return are purportedly               
          based on local real estate tax assessments for 1991 (as opposed             
          to 1990); (3) the adjustment described in paragraph (h) of the              
          explanation of adjustments has no basis in law or fact; and (4)             
          the adjustment described in paragraph (i) of the explanation of             
          adjustments contains certain errors in respect of both the date             
          of the transfer in question and the identity of the financial               
          institution involved in the transfer.  In short, we are not                 
          impressed with any of these contentions.  Taking the notice of              
          deficiency as a whole, the errors and flaws that petitioner                 
          relies on, while perhaps causing minor confusion, do not                    
          demonstrate that respondent failed to make the requisite                    
          "determination" contemplated by section 6212(a).  See Mayerson v.           
          Commissioner, 47 T.C. 340, 348-349 (1966); Saint Paul Bottling              
          Co. v. Commissioner, 34 T.C. 1137 (1960).                                   
          We likewise reject petitioner's invitation to "carve out a                  
          narrow extension of Scar", to be applied in cases involving so-             







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