Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 17

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          called "gross ineptitude".8  In our view, an extension of Scar in           
          this manner would, as a general rule, directly conflict with the            
          well-settled rule that, absent extraordinary circumstances, we              
          will not look behind a notice of deficiency.  Riland v.                     
          Commissioner, 79 T.C. 185, 201 (1982); Jackson v. Commissioner,             
          73 T.C. 394, 400 (1979); Greenberg's Express, Inc. v.                       
          Commissioner, 62 T.C. 324, 327-328 (1974).  We fail to see any              
          extraordinary circumstances in the present case justifying a                
          probe into respondent's motives and procedures leading to the               
          issuance of the notice of deficiency.                                       
          In addition to arguing that the notice of deficiency is                     
          invalid under Scar, petitioner maintains that the notice of                 
          deficiency might be deemed invalid by virtue of respondent's                
          failure to comply with section 7517.  Section 7517, enacted as              
          section 2008(a)(1) of the Tax Reform Act of 1976, Pub. L. 94-455,           
          90 Stat. 1520, 1891, provides in pertinent part:                            
               (a) General Rule.--If the Secretary makes a                            
               determination or a proposed determination of the value                 
               of an item of property for purposes of the tax imposed                 
               under chapter 11, 12, or 13, he shall furnish, on the                  
               written request of the executor, donor, or the person                  
               required to make the return of the tax imposed by                      
               chapter 13 (as the case may be), to such executor,                     

          8  Petitioner's reliance on Pearce v. Commissioner, 95 T.C.                 
          250 (1990), revd. without published opinion 946 F.2d 1543 (5th              
          Cir. 1991), is misplaced.  For the reasons explained in Stinnett            
          v. Commissioner, T.C. Memo. 1993-429, we shall not reconsider our           
          opinion in Pearce v. Commissioner, supra, or its reversal by the            
          Fifth Circuit, in deciding this case.  See 5th Cir. R. 47.5.1,              
          47.5.2, 47.5.3.                                                             




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