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13, 1991, was not appealed, and became final 30 days later.
Legislation purporting to authorize the reopening of that final
judgment and the reinstatement of the complaint was signed into
law by the President on December 19, 1991. The Supreme Court
held that the retroactive legislation was unconstitutional to the
extent it required Federal courts to reopen judgments that became
final before its enactment. Plaut v. Spendthrift Farm, supra.
Plaut is distinguishable because the amendment to section
7436 does not require the reopening of judgments which had become
final prior to the amendment’s enactment. Cf. Plaut v.
Spendthrift Farm, supra at 214-217. Vacating the order was
within our authority and consistent with the amendment and its
effective date. See sec. 7436(a). Moreover, our judgment in
this case is not yet final. See sec. 7481(a); Rule 190(a).
Consequently, Plaut is inapplicable. Accordingly, this Court’s
decision to vacate its October 14, 1999, order was proper.
Neely v. Commissioner, 116 T.C. 79, 84 n.6 (2001).
B. Notice of Determination
Petitioner contends that the notice of determination is
invalid because “the unexplained arrows and rounding of * * *
[the amounts used to determine the deficiencies] indicate
vagueness.” Challenges regarding the validity of a notice of
determination are analogous to such challenges to a notice of
deficiency. Henry Randolph Consulting v. Commissioner, 113 T.C.
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