Jill R. Scott - Page 7

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          filing the petition".  60 T.C. 1089.  We agree with respondent                     
          that the petition filed in this case contains no mention of the                    
          1993 taxable year--the only year placed in dispute in the                          
          petition is the 1992 taxable year.  Moreover, even if we were to                   
          view petitioner's objection to respondent's motion to dismiss as                   
          an attempt to amend the petition to place the 1993 year in                         
          dispute, the objection was not filed within the statutory period                   
          for filing the petition.  In fact, the petition itself was not                     
          timely filed with respect to either the notice of deficiency for                   
          1992 or the notice of deficiency for 1993.  There appears to be                    
          no dispute that the joint notice of deficiency issued for the                      
          1993 taxable year was sent to petitioner's last known address                      
          (the same address reflected by petitioner in the petition).                        
                In any event, petitioner's contention that the notice of                     
          deficiency for 1993 is invalid plainly lacks merit.  We                            
          understand petitioner to contend that the notice is invalid on                     
          the ground that respondent did not determine a deficiency within                   
          the meaning of section 6212(a).  See Scar v. Commissioner, 814                     
          F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855 (1983).                               
                Normally, the Court will not look behind the notice of                       
          deficiency to examine the basis for the Commissioner's motives or                  
          administrative policies or procedures in making the                                
          determinations reflected in the notice.  See Riland v.                             
          Commissioner, 79 T.C. 185, 201 (1982); Greenberg's Express, Inc.                   
          v. Commissioner, 62 T.C. 324, 327 (1974).  However, in Scar v.                     



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