- 9 - trying to circumvent the statute of limitations. We disagree for reasons stated next. A. Whether Respondent's Notice of Deficiency Is Valid Petitioner contends that we lack jurisdiction because respondent's notice of deficiency is invalid. 1. Effect of Petitioner's Denial That He Received Any Economic Benefit From the �570,000 Settlement Petitioner received a �570,000 bank draft payable to Swiss Bank Corp. from Kenning on or about May 7, 1987. Petitioner contends that respondent knew that the payment from Kenning was made in settlement of A.T.O.'s lawsuit with Kenning, and that petitioner was a director of A.T.O. Before respondent issued the proposed adjustment letter on May 3, 1995, petitioner gave respondent a written statement (not under oath) in which petitioner denied receiving any personal benefit from the �570,000. Petitioner contends that respondent had no basis for determining that petitioner benefited personally from the settlement funds. Petitioner points out that respondent did no net worth analysis. Petitioner contends that respondent based the notice of deficiency on mere suspicion and that the notice of deficiency is invalid. We disagree. To be valid, a notice of deficiency must fairly advise the taxpayer that the Commissioner has actuallyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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