James D. and Rita K. Snyder - Page 16




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               deficiency to the taxpayer by certified mail or                        
               registered mail”); see also Commissioner v. Oswego                     
               Falls Corp., 71 F.2d 673, 677 (2d Cir. 1934) (notice of                
               deficiency need not be signed).  Moreover, in Scar v.                  
               Commissioner, we held that “no particular form is                      
               required for a valid notice of deficiency * * * and the                
               Commissioner need not explain how the deficiencies were                
               determined.”  814 F.2d 1363, 1367 (9th Cir. 1987)                      
               (citation omitted).  * * *                                             
          Urban v. Commissioner, 964 F.2d 888, 889-890 (9th Cir. 1992),               
          affg. T.C. Memo. 1991-220.  In Scar v. Commissioner, 814 F.2d               
          1363, 1367 (9th Cir. 1987), 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).  We have examined the notice and, on its              
          face, it does not reveal that respondent failed to make a                   
          determination:  It is addressed to petitioners, references their            
          1992 through 1995 tax years, states both that respondent has                
          determined that petitioners owe additional tax or other amounts             
          (or both) for such years and the size of those amounts, and sets            






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