Walter T. McGee - Page 17

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          the amounts of tax due, interest, and any additional amounts,               
          additions to tax, and assessable penalties.  Sec. 7522(a) and               
          (b).  An inadequate description does not invalidate the notice.             
          Sec. 7522(a).                                                               
               Here, the notice of deficiency clearly describes the basis             
          for respondent's determination.  Respondent's basis for the                 
          determination is that petitioner received the �570,000, A.T.O.              
          records do not show that A.T.O. received the funds, and                     
          petitioner refused to give respondent information showing that he           
          did not benefit from the settlement funds.  We conclude that the            
          notice of deficiency describes the basis for and amounts of tax             
          and penalties due as required by section 7522.                              
               6.   Conclusion                                                        
               We conclude that the notice of deficiency is valid.                    
          B.   Judicial Notice of Writ of Summons                                     
               Petitioner asks us to take judicial notice of a Writ of                
          Summons issued by a British court which notifies Kenning that               
          A.T.O. has filed a claim and that Kenning may pay or contest the            
          claim within 14 days.  Petitioners ask us to take notice of this            
          document to prove that A.T.O. sued Kenning.  We need not do so              
          because the parties do not dispute the fact that A.T.O. sued                
          Kenning.  Thus, this issue is moot.                                         









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