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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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Last modified: May 25, 2011