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generated by those acts. For example, it is undisputed that
petitioner, a licensed real estate salesperson, worked for WWMC
and a few other parties during 1993. It is also undisputed that
WWMC and the other parties paid a total of $103,420 for
petitioner’s services during that year. Moreover, it is clear
that this $103,420 was deposited into Universal’s bank account,
that petitioner was one of the signatories to that account, and
that petitioner wrote checks on that account. Finally, it is
clear that petitioner was one of the original capital unit
holders of Universal, and as such was once entitled to receive
distributions of income and corpus from Universal. All this more
than amply links petitioner with the unreported income described
in the notice.
Petitioner asserts that, as a matter of law, none of this
evidence may be used to support the statutory notice, because:
(1) Respondent has not shown that respondent had the evidence
when the notice was issued, and (2) the evidence was not
described in the notice itself. We disagree.
In general, any admissible evidence may be used to support a
deficiency notice. See Cook v. United States, 46 Fed. Cl. 110
(2000), which stated that an assessment was not “naked” even if
the administrative file supporting its entry was lost, because:
what is critical, given the de novo nature of the
proceedings * * * is that admissible evidence exists to
support the assessment. If such evidence exists, and
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