Anne M. Rogers - Page 4




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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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