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analogy in equating the list of workers reclassified with the
amount of a deficiency. Respondent notes that section 7522,
effective for notices sent on or after January 1, 1990, provides
certain requirements for the statutory notice but also provides
that "inadequate description" of the amount "shall not invalidate
such notice."
Section 6212 is not among those sections referred to in
section 7436(d), which provides that the principles of certain
other sections shall apply to cases arising under section 7436.
Nonetheless, we agree with the parties that a general analogy to
cases involving deficiency notices is useful. We do not agree
with petitioner, however, that those cases suggest that the
notice in this case is fatally defective.
We need not discuss every case cited by either party.
Specifically, discussions of circumstances in which the Court
will or will not examine events occurring prior to the time a
notice was sent are not useful here. Inasmuch as petitioner
acknowledges that it has not been misled and asserts that "this
is not a question of being misled," we need not discuss cases in
which inconsistencies in a notice arguably created confusion.
Nor need we discuss cases in which the notice showed on it face
that there was no determination, such as Scar v. Commissioner,
814 F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855 (1983), or cases
limiting the application of Scar, such as Clapp v. Commissioner,
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