- 16 - 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-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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