Helena Culver Fraser - Page 4

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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                      
               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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