- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011