- 13 - Cir. 1989) (Commissioner's subpoenas were burdensome and late). The cases petitioner cites do not support his contention that we lack jurisdiction. 3. Whether the Notice of Deficiency Is Invalid Because It Did Not State That Respondent Had 6 Years To Assess Tax Respondent mailed the notice of deficiency more than 3 and less than 6 years after petitioner filed his return for 1987. Respondent contends that respondent has 6 years to assess tax under section 6501(e)(1)(A) because petitioner omitted more than 25 percent of his gross income. Petitioner contends that respondent must assert grounds in the notice of deficiency to support respondent's reliance on section 6501(e)(1)(A). Petitioner contends that Portillo v. Commissioner, supra; Reis v. Commissioner, 1 T.C. 9 (1942), affd. 142 F.2d 900 (6th Cir. 1944); and Stoller v. Commissioner, T.C. Memo. 1983-319, establish that the notice of deficiency is invalid because respondent did not state grounds for relying on the 6-year period to assess tax. We disagree. In the notice of deficiency, respondent determined that petitioner reported income of $29,577 for 1987 and failed to report income of $965,425. It is clear from the notice of deficiency that respondent determined that petitioner's unreported income exceeded 25 percent of his gross income. Thus,Page: 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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