Western Management, Inc. - Page 8

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          250 (1999) (holding that a notice of determination was not                  
          invalid for failure to specify the names of the individuals whose           
          status had been determined pursuant to section 7436).  A notice             
          of deficiency is not “invalid for failure to explain the                    
          adjustments, failure to cite statutory provisions on which                  
          respondent relied, or inconsistencies in the notice [of                     
          deficiency].”  Id. at 253; Campbell v. Commissioner, 90 T.C. 110            
          (1988); Mayerson v. Commissioner, 47 T.C. 340, 348-349 (1966).              
          There is no dispute that the name of the taxpayer, the affected             
          tax periods, and the amounts of the deficiencies are set forth in           
          the notice of determination.  Generally, the Court will not                 
          examine respondent’s motives or procedure leading to his                    
          determination relating to a notice of deficiency.  See Riland v.            
          Commissioner, 79 T.C. 185, 201 (1982); Greenberg's Express, Inc.            
          v. Commissioner, 62 T.C. 324, 327 (1974).  Similarly, petitioner            
          has not identified any reason to examine respondent’s motives or            
          procedure leading to his determination pursuant to section 7436.            
               C.   Kovacevichs’ 1994 FICA Tax Payment                                
               On October 17, 2000, the Court filed petitioner’s motion to            
          dismiss on the ground that the Court lacks jurisdiction because             
          the Kovacevichs allegedly paid all of their 1994 FICA taxes.  Our           
          jurisdiction, pursuant to section 7436, is based upon whether               
          petitioner properly classified Kovacevich as an independent                 
          contractor and whether petitioner is entitled to section 530                






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