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There is nothing on the face of the notice that suggested no
determination was made prior to the time the notice was sent.
There is no dispute that the name of the taxpayer and the
affected tax periods are set forth in the notice. In Randolph
Consulting I, 112 T.C. at 12, we concluded that section 7436 is
more like the declaratory judgment provisions than like the
deficiency jurisdiction under which we may redetermine the amount
of tax due. Petitioner has not cited, and we have not found, any
declaratory judgment case in which a notice of determination was
held inadequate. (Cases involving a taxpayer's attempt to invoke
our jurisdiction on the basis of a document that was not a notice
of final determination have been dismissed on respondent's
motions. See AHW Corp. v. Commissioner, 79 T.C. 390 (1982); New
Community Senior Citizen Housing Corp. v. Commissioner, 72 T.C.
372 (1979).)
Petitioner's contention that the notice is invalid for
failure to specify the individual or individuals whose status has
been determined, therefore, is only comparable or analogous to
arguments by taxpayers that a notice was invalid for failure to
explain the adjustments, failure to cite statutory provisions on
which respondent relied, or inconsistencies in the notice. The
cases have held that none of the asserted inadequacies
invalidates the notice. See, e.g., Campbell v. Commissioner, 90
T.C. 110 (1988); Mayerson v. Commissioner, 47 T.C. 340, 348-349
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