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addition to tax under section 6651(a)(1) if such addition is
determined by the amount of tax shown on the taxpayer’s return.
See secs. 6665(b), 6201(a)(1); Meyer v. Commissioner, 97 T.C.
555, 559 (1991). The summary assessments described above are
assessments that are not subject to the deficiency procedures and
are not within the jurisdiction of this Court. Meyer v.
Commissioner, supra at 560.
The amount shown as tax by petitioner on her first amended
return does not constitute a deficiency within the meaning of
section 6211(a). Wilson v. Commissioner, 118 T.C. 537 (2002);
301.6211-1(a), Proced. & Admin. Regs. Further, an addition to
tax under section 6651(a)(1) is not subject to the deficiency
procedures if such addition is determined by the amount of tax
shown on the taxpayer’s return. Meyer v. Commissioner, supra at
562.
The addition to tax of $6,570.68 that respondent determined
under section 6651(a)(1) was computed by reference to the tax
shown by petitioner on her delinquently filed amended return;
thus, pursuant to section 6665(b), the addition to tax is not
attributable to a deficiency as defined in section 6211. See
Estate of Forgey v. Commissioner, 115 T.C. 142, 146-148 (2000);
Meyer v. Commissioner, supra at 559-563.
Since we have determined above that the amount of tax shown
on the amended return is not a deficiency and the section
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