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dismiss for lack of jurisdiction, raised the issue that
respondent’s notice of deficiency incorrectly indicated ending
dates for petitioner’s taxable years, that the notice of
deficiency therefore was invalid, and that the Court lacks
jurisdiction over petitioner’s actual 1990 through 1994 taxable
years.
In making the above adjustments to petitioner’s consolidated
income and expenses for each year, respondent did not make any
adjustment, and respondent did not charge petitioner with any
item of income or adjust any expense item relating to the 2 or 4
days that were reflected in the notice of deficiency and that
were not part of petitioner’s 1990 through 1994 taxable years.
During respondent's audit of petitioner's 1990 through 1994
consolidated corporate Federal income tax returns, the accounting
firm of Arthur Andersen represented petitioner. Petitioner's
representatives from Arthur Andersen met with respondent,
discussed legal and factual issues, and later prepared and filed
the protest and the petition.
OPINION
Validity of Notice of Deficiency
Litigation in this Court requires as a jurisdictional
prerequisite a valid notice of deficiency. Sec. 6213(a). The
notice must indicate the taxable period involved or provide
sufficient information that the taxpayer reasonably could not be
misled as to the taxable period involved. Commissioner v. Forest
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