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C. Discussion
1. Validity of Notice
Petitioner claims that the notice is invalid because
respondent failed to determine a deficiency in petitioner’s
income tax or examine its return.
Section 6212(a) authorizes the Secretary to send a notice of
deficiency in respect of certain taxes, including the income tax.
We have jurisdiction to redetermine deficiencies determined by
the Secretary. See sec. 6214(a). A valid notice of deficiency
has been described as the “ticket to the Tax Court”. E.g.,
Baron v. Commissioner, 71 T.C. 1028, 1034 (1979). Petitioner
directs us to Scar v. Commissioner, 814 F.2d 1363 (9th Cir,
1987), revg. 81 T.C. 855 (1983). In Scar, the Court of Appeals
for the Ninth Circuit considered a notice of deficiency that, on
its face, revealed that no determination of a deficiency had been
made with respect to the taxpayers in question for the year in
question. See id. at 1370. The Court of Appeals held that such
a notice was invalid and the petition contesting such notice
should have been dismissed in the taxpayers’ favor for lack of
jurisdiction. See id. Commenting on Scar, we have held: “Where
the notice of deficiency does not reveal on its face that the
Commissioner failed to make a determination, a presumption arises
that there was a deficiency determination.” Campbell v.
Commissioner, 90 T.C. 110, 113 (1988).
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