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whatever source derived," including compensation for services and
interest income. Sec. 61(a)(1), (4). In addition, section 85
includes unemployment compensation in gross income. Respondent
determined petitioner's deficiencies for the years in issue under
subtitle A, to which the deficiency notice procedures apply.
Sec. 6211(a). Respondent issued a notice of deficiency, and
petitioner invoked the jurisdiction of this Court by filing a
petition in response to that notice of deficiency. Rule 13(a),
(c); Levitt v. Commissioner, 97 T.C. 437, 441 (1991).
Petitioner also contends that we lack jurisdiction because
the notice of deficiency issued by respondent was invalid.
Petitioner bases her claim of the invalidity of the deficiency
notice on the ground that respondent did not make a determination
of her deficiency as required by section 6212, citing Scar v.
Commissioner, 814 F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855
(1983). Section 6212(a) authorizes the Commissioner to mail a
notice of deficiency to a taxpayer after determining a
deficiency.
The Commissioner must consider information relating to a
particular taxpayer to make her determination of a deficiency
with respect to that taxpayer. Scar v. Commissioner, supra at
1368. A presumption exists that the Commissioner made a
determination if the notice reveals that the deficiency was based
on information relating to the taxpayer. Clapp v. Commissioner,
875 F.2d 1396, 1402 (9th Cir. 1989). Absent exceptional
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