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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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