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In the instant case, respondent used a line-by-line
compilation of petitioner's tax return information. Petitioner
does not dispute that the amounts appearing on the RTVUE are the
same as the amounts appearing on his 1994 return. Additionally,
respondent did not merely utilize the maximum tax bracket in this
case.
Therefore, it is clear in this case that a valid
determination was made. The RTVUE records allowed respondent to
consider taxpayer specific information and reconstruct
petitioner's return for the purposes of the examination. The
RTVUE was used as a substitute for petitioner's 1994 return as it
was a line-by-line summary of the actual return. Not only did
respondent examine the return information, there were
communications between respondent's examining agent and
petitioner with respect to the adjustments at issue.
Petitioner's other contentions contained in his motion are
not based on the validity of the notice or the attached schedules
but are directed at perceived problems with the appeals and audit
process which we need not address and which do not deprive this
Court of jurisdiction. We find that the notice of deficiency in
this case was valid and hold that this Court
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