Win H. Emert - Page 5




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          Primo Pants Co. v. Commissioner, supra; Hitachi Sales Corp. of              
          Am. v. Commissioner, supra.                                                 
               Accordingly, we hold that a section 481 adjustment is a                
          proper matter for Rule 155 consideration.                                   
               To reflect the foregoing,                                              
                                                  An appropriate order will           
                                             be issued.                               

























               4(...continued)                                                        
          describe the basis on which the Commissioner relied to support              
          the Commissioner's deficiency determination.  See also sec. 7522.           
          In the case at bar, however, sec. 481 is more than implicit in              
          the notice; it is patent.                                                   




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