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taxpayer. See Benzvi v. United States, 787 F.2d 1541 (11th Cir.
1986).
In this case, respondent never determined a deficiency for
any particular year and never sent the reviewer’s proposal to
petitioners. Accordingly, the reviewer’s proposal does not
constitute a “notice of deficiency” within the meaning of section
7430(c)(7). See also Estate of Gillespie v. Commissioner, 103
T.C. 395, 397 (1994) (30-day letter not a notice of deficiency
for purposes of section 7430).
Petitioners further contend that the term “notice of
deficiency” in section 7430(c)(7) should not be given the same
meaning it has under section 6212, and that for purposes of
section 7430(c)(7)(B)(ii) it is inconsequential that the
reviewer’s proposal was neither issued nor sent to them. Again,
we disagree.
We have previously found, and the Regulations provide, that
the meaning of the term “notice of deficiency” in section 7430(c)
is the same as the meaning of that term in section 6212. See
Estate of Gillespie v. Commissioner, supra; sec. 301.7430-
3(c)(3), Proced. & Admin. Regs.. Under well-established rules of
statutory construction, identical words used in different parts
of the same statute are to be given a similar meaning in the
absence of a contrary legislative intent. See Helvering v.
Stockholms Enskilda Bank, 293 U.S. 84, 87 (1934). We find no
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