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Petitioner's assertions that respondent failed to identify
the statute or regulation relied upon in issuing the notices, and
that respondent failed to observe all of the requirements of the
Internal Revenue Manual also are without merit. Lack of
reference or citation to the Internal Revenue Code does not
invalidate a notice of deficiency. See Jarvis v. Commissioner,
supra; McCabe v. Commissioner, T.C. Memo. 1985-202. Internal
Revenue Manual procedures are generally directory in nature and
not mandatory, and the alleged procedural violations herein are
not of a kind that would render respondent's determinations
invalid. See United States v. Horne, 714 F.2d 206, 207 (1st Cir.
1983); Vallone v. Commissioner, supra at 806-808; Levy v.
Commissioner, T.C. Memo. 1987-609, affd. without published
opinion 884 F.2d 574 (5th Cir. 1989).
Finally, petitioner's contention that the notices of
deficiency were not timely issued is frivolous. Petitioner
contends that the Forms W-2 filed by her employers with the
Internal Revenue Service satisfied her filing requirement and
triggered the limitations period for assessment. In support of
this argument, petitioner referenced Income Tax regulations in
effect during 1946. For taxable years 1944 through 1947, Income
Tax regulations provided that individuals required to file were
to file their tax returns on Form 1040 or, under certain
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