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similar to an argument that the Court addressed in Campbell v.
Commissioner, 90 T.C. 110 (1988). In Campbell, the Commissioner
mailed a notice of deficiency to the taxpayers including: (1) A
cover letter reciting in standard language that it was a notice
of deficiency and listing the taxable year as well as the amounts
of the deficiency and additions to tax; (2) a notice of
deficiency waiver form; and (3) several pages purportedly
explaining the adjustments. Although the cover letter and the
waiver clearly related to the taxpayers, the Commissioner had
inadvertently attached to the notice a seven-page explanation of
adjustments for an unrelated taxpayer. In response, the
taxpayers filed a petition (and later a motion to dismiss)
attacking the validity of the notice of deficiency. See id. at
111.
Upon review of the matter, we noted that the first two pages
of the deficiency notice clearly referred to the taxpayers as the
subjects of the notice. While the explanation of adjustments may
have caused confusion, there was no indication in the notice that
the Commissioner failed to consider information relating to the
taxpayers in making the deficiency determination. See id. at
113. Viewing the record as a whole, we concluded that the
Commissioner had determined a deficiency against the taxpayers
and inadvertently attached the wrong computational sheets to the
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