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form of a notice or the specifics to be contained therein);
Rogers v. Commissioner, T.C. Memo. 2001-20, affd. without
published opinion 281 F.3d 1278 (5th Cir. 2001). Likewise, a
failure to include a statutory citation for each adjustment in a
notice does not invalidate a notice under section 7522. Sec.
7522(a). Section 7522(a) requires a notice of deficiency to
describe the bases for, and identify the amounts of, tax and
additions to tax, but it contains no requirement that a notice of
deficiency identify the specific statutory provision supporting
each adjustment.
The notice of deficiency described the income adjustments in
sufficient detail to put petitioner on notice of the adjustments
against him. See Jarvis v. Commissioner, supra at 655. We hold,
therefore, that the failure to identify the statutory provision
requiring respondent’s income adjustments in the notice of
deficiency does not render the notice invalid.
II. Additions to Tax
A. Respondent’s Burden of Production Under Section 7491(c)
Section 7491(c) was enacted by section 3001(a) of the
Internal Revenue Service Restructuring and Reform Act of 1998
(RRA 1998), Pub. L. 105-206, 112 Stat. 726, and applies to court
proceedings arising in connection with examinations commencing
after July 22, 1998. RRA 1998 sec. 3001(c)(1), 112 Stat. 727.
Section 7491(c) provides:
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