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Section 6213(b)(1) in general allows the assessment of tax
in excess of that shown on a return (i.e., without resort to the
deficiency procedures of sections 6211-6216) in cases where the
additional amount of tax is attributable to "a mathematical or
clerical error appearing on the return". Section 6213(g)(2)
defines "mathematical or clerical error" for this purpose
generally as an error in addition, subtraction, multiplication,
or division shown on a return; an incorrect use of an IRS table
if apparent from the existence of other information on a return;
an item entry on a return which is inconsistent with another
entry of the same or another item on the return; an omission of
information which is required to be supplied on a return to
substantiate an entry; an entry on a return of a deduction in an
amount which exceeds a statutory limit if the items entering into
the computation of the limit appear on the return; and various
other instances not pertinent here. See sec. 6213(g)(2)(A)-(M).
As noted in our findings of fact, respondent's "math error"
adjustments to the 1999 return included a correction of
inconsistent entries for adjusted gross income and of a casualty
loss claimed without regard to the limitation of such losses to
amounts exceeding 10 percent of adjusted gross income. We have
no quarrel with these adjustments, as they fall squarely within
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