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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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