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determined a deficiency and specify the year and amount.2 Sealy
Power Ltd. v. Commissioner, 46 F.3d 382, 386 (5th Cir. 1995),
affg. in part and revg. and remanding on other issues T.C. Memo.
1992-168; Abrams v. Commissioner, 787 F.2d 939, 941 (4th Cir.
1986), affg. 84 T.C. 1308, 1310 (1985); Mayerson v. Commissioner,
47 T.C. 340, 348-349 (1966). The notice of deficiency here
clearly shows that respondent determined that petitioner had an
income tax deficiency of $369,390 for 1987 and was liable for
additions to tax for 1987 of $92,348 for failure to timely file
under section 6651(a)(1) and $92,348 for substantial
understatement of tax under section 6661. The explanation that
respondent attached to the notice of deficiency stated that
petitioner had received the �570,000 in a settlement; that
respondent asked petitioner and his counsel for information about
petitioner's disposition of the settlement, but they refused to
provide it; that respondent was unable to trace the settlement
proceeds to anyone other than petitioner; that respondent checked
the books and records of A.T.O. and found no reference to the
�570,000; and that petitioner had told a successor to A.T.O. that
the �570,000 settlement had been disbursed, but petitioner
provided no further information to A.T.O.'s successor.
2 We discuss sec. 7522 below at par. A-5.
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