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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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