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Finally, we observe that Congress has provided adequate
remedies for taxpayers confronted with an inaccurate deficiency
determination. In light of remedies such as shifting the burden
of proof to respondent and/or awarding litigation costs,
petitioner's call for an expanded substantive review of the
matters leading to respondent's determination is unwarranted.
See Clapp v. Commissioner, 875 F.2d 1396, 1403 (9th Cir. 1989);
Powers v. Commissioner, 100 T.C. 457 (1993).
Consistent with the foregoing, we shall deny petitioner's
motion to dismiss for lack of jurisdiction.
To reflect the foregoing,
An order denying petitioner's
Motion to Dismiss for Lack of
Jurisdiction, As Amended, and
petitioner's Motion to Strike will
be issued.
9(...continued)
information contemplated under Rule 70(a) or later through formal
discovery requests such as a request for production of documents.
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