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deficiencies were determined. See Benzvi v. Commissioner, 787
F.2d 1541, 1542 (11th Cir. 1986); Barnes v. Commissioner, 408
F.2d 65, 68 (7th Cir. 1969) (citing Commissioner v. Stewart, 186
F.2d 239, 242 (6th Cir. 1951), revg. a Memorandum Opinion of this
Court), affg. T.C. Memo. 1967-250. In Stoecklin v. Commissioner,
865 F.2d 1221 (11th Cir. 1989), affg. T.C. Memo. 1987-453, the
Court of Appeals for the Eleventh Circuit required that “A
deficiency notice * * * at a minimum must show that * * * ‘a
deficiency exists for a particular year and specify the amount of
the deficiency.’” Id. at 1224 (quoting Benzvi v. Commissioner,
supra at 1542)). Similarly, this Court has stated that “the
notice is only to advise the person who is to pay the deficiency
that the Commissioner means to assess him; anything that does
this unequivocally is good enough.” Jarvis v. Commissioner, 78
T.C. 646, 655-656 (1982) (quoting Olsen v. Helvering, 88 F.2d
650, 651 (2d Cir. 1937)).
Respondent argues that his adjustments are based on the
limitation of the partnership losses to the partner’s basis in
the partner’s partnership interest, the at-risk limitation under
section 465, and the passive loss limitation rules under section
469. We have previously held that each of these items is unique
to the individual characteristics of each partner and does not
have a uniform effect on all of the partners. Estate of Quick v.
Commissioner, 110 T.C. 172, 188 (1998) (holding that a passive
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