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Petitioner mailed her petition on August 25, 2004, and it
was filed September 2, 2004. Trial was held on March 27, 2006.
OPINION
Petitioner admits she received the notice of deficiency and
that it correctly states her Social Security number and address.
Petitioner contends, however, that the notice of deficiency is
invalid because it identifies her by her previous married name,
Christina L. Gore, rather than her current married name of
Christina L. Belmont.
The Code does not prescribe the form the notice of
deficiency must take, but it must “describe the basis for, and
identify the amounts (if any) of, the tax due, interest,
additional amounts, additions to the tax, and assessable
penalties included in such notice.” Sec. 7522. An inadequate
description does not invalidate the notice. Id. We have stated:
“‘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)). The notice of
deficiency petitioner received was sufficient to fairly advise
her of the basis for the deficiency in income tax and additions
to tax and the year and amounts thereof. The notice of
deficiency is valid.
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