- 7 - determined deficiencies in the amounts of $18,232 and $13,074 relating to 1992 and 1994, respectively. See Perlmutter v. Commissioner, 44 T.C. 382, 400 (1965)(holding that a valid notice of deficiency indicates that the respondent has determined a deficiency in tax in a definite amount for a particular taxable year and intends to assess the tax in due course), affd. 373 F.2d 45 (10th Cir. 1967). A notice of deficiency is not invalid for failure to explain the adjustments or to cite statutory provisions on which respondent relied. See, e.g., Henry Randolph Consulting v. Commissioner, 113 T.C. 250, 253 (1999); Campbell v. Commissioner, 90 T.C. 110 (1988); Mayerson v. Commissioner, 47 T.C. 340, 348-349 (1966); St. Paul Bottling Co. v. Commissioner, 34 T.C. 1137 (1960). Accordingly, we reject petitioners’ contention. II. Unreported Income Petitioners contend that it was inappropriate for respondent to use the “specific item” method to determine petitioners’ deficiencies. The “specific item” method is an indirect method of income reconstruction, which consists of evidence of specific amounts of income received by a taxpayer and not reported on the taxpayer’s return. Estate of Beck v. Commissioner, 56 T.C. 297, 361 (1971). It is well settled that taxpayers are required to report every item of income received and maintain records to establish the correct amount of income, deductions, and creditsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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