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with sufficient specificity in the notice of deficiency, inasmuch
as "only a general explanation" is offered. Respondent, on the
other hand, maintains that the notice of deficiency provides an
adequate explanation of adjustments, and thus a shift of the
burden of proof is not warranted. We agree with respondent.
The general rule of law is clear that, upon the issuance of
a timely notice of deficiency by respondent, the burden of
proving the determinations in such notice to be erroneous is on
the taxpayer. Rule 142(a) states that the burden of proof shall
be on the petitioner except as otherwise provided by statute or
"determined by the Court".
As relevant here, section 7522(a) provides that any "notice
* * * shall describe the basis for, and identify the amounts (if
any) of, the tax due". Section 7522(b) specifies that these
provisions shall apply to, among others, any notice "described in
section * * * 6212". See Ludwig v. Commissioner, T.C. Memo.
1994-518. Section 6212 pertains to notices of deficiency, as
here. Upon examination, the notice of deficiency issued to
petitioners specifically provides the primary position determined
by respondent, details an alternative position, and calculates a
deficiency of $283,078 for petitioners based upon the primary
position.
Based on the foregoing discussion, we hold that respondent
has met the requirements of section 7522. We therefore decline
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