- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011