- 7 -
correct amount of the deficiency as of the date a decision is
entered by the Court; the entire deficiency need not have existed
at the time the notice of deficiency was mailed. Id. Thus, a
computation under Rule 155 will be necessary in this case to
calculate the correct amount of the remaining deficiency with
respect to petitioner’s overall tax liability of $8,950, taking
into account any abatement by respondent. If an abatement has
not been made by respondent with respect to the prior assessment
of $7,398, however, the amount of the deficiency cannot exceed
petitioner’s total tax liability less the amount of this
assessment. Sec. 6211(a)(1)(B); Heasley v. Commissioner, supra.
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011