- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007