- 4 - additional amounts, additions to tax, and assessable penalties included in such notice. An inadequate description under the preceding sentence shall not invalidate such notice.” There is no requirement that legal citations be included in the statutory notice mailed to petitioner. See Jarvis v. Commissioner, 78 T.C. 646, 655-656 (1982). The notice in this case set out the specific items of unreported income received by petitioner and the other amounts required under section 7522. The notice sent to petitioner is sufficient for all relevant purposes of this case. Petitioner also argues that she was entitled to a hearing with the IRS Appeals Division before the notice of deficiency was sent. There is no such requirement, and it is apparent, based on petitioner’s arguments, that any such hearing would have been futile. Similarly, we reject her request that the case be “remanded” to the IRS for further consideration of her arguments. Petitioner’s Income Tax Liability Petitioner makes a convoluted argument that subjecting her to the same rate of taxes as Federal employees constitutes impermissible “disparate tax treatment.” Petitioner cites a variety of Code sections and regulatory materials to show that public employees receive benefits from the Federal Government that are not available to her as an employee of private industry. She argues:Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011