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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:
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