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Petitioner’s contention that the notice of deficiency is
invalid because respondent did not adequately explain the basis
for his determination was specifically rejected in the Scar
opinion itself: “the Commissioner need not explain how the
deficiencies were determined.” Scar v. Commissioner, 814 F.2d at
1367. Similarly, petitioner’s contention that the blanket denial
of deductions renders the notice of deficiency invalid was
rejected by the Court of Appeals for the Ninth Circuit in both
Clapp v. Commissioner, supra, and Kantor v. Commissioner, supra.
Petitioner does not allege that the notice of deficiency
shows on its face that the determination relates to another
person or that the tax rates were arbitrarily set. Petitioner’s
allegation that the notice of deficiency was erroneous or even
arbitrary does not raise a proper challenge to its validity under
Scar. Petitioner’s counsel should have known after only a
cursory reading of the cases that the Scar exception does not
apply to the case at hand.
We also reject out of hand petitioner’s unsupported argument
that respondent acted improperly in disallowing all deductions in
the notice of deficiency. Respondent made more than reasonable
efforts to obtain from petitioner records to support the
deductions that petitioner had claimed on his tax returns.
Petitioner refused to produce documentation to support his
deductions. He made unwarranted demands on respondent to reply
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