Christina L. Belmont - Page 4




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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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