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opportunity to petition this Court for a redetermination of that
deficiency. Id.
In Scar v. Commissioner, 814 F.2d 1363, 1368 (9th Cir.
1987), revg. 81 T.C. 855 (1983), the Court of Appeals for the
Ninth Circuit held that respondent must consider information
relating to a particular taxpayer before respondent can be said
to have determined a deficiency with respect to that taxpayer.
For purposes of determining whether the notice of deficiency
provides sufficient information to apprise the taxpayer that the
Commissioner has determined a deficiency in tax, a notice of
deficiency includes the cover page and all attached pages and
documents. Smith v. Commissioner, T.C. Memo. 1979-16.
If a notice of deficiency otherwise fulfills its purpose, we
have held that a mathematical error in the notice will not
invalidate the notice where the taxpayer is not misled by the
error. See Myers v. Commissioner, T.C. Memo. 1981-84; see also
Smith v. Commissioner, supra.
Despite a trivial transposition error on the cover page of
the notice of deficiency, petitioner was adequately informed of
the income tax and issues in controversy by the notice of
deficiency. The petition indicates that petitioner was not
misled by the transposition error; rather, petitioner was fully
aware of the typographical error’s existence. The notice of
deficiency was not misleading and put petitioner on notice that
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