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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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Last modified: May 25, 2011