Rosa Janus - Page 9

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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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