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the sole jurisdictional issue is whether respondent issued a
valid notice of deficiency. Petitioner has presented no evidence
that the notice is invalid, and, as set forth below, petitioner’s
attacks on the notice are without merit. Contrary to the order
of the Court, petitioner did not file an opening brief.
Respondent did file an opening brief, and, in that brief, he
addresses the arguments that he believes were clearly raised by
petitioner. Petitioner filed an answering brief, and, in that
brief, directed his arguments to the points respondent raised.
We assume that those points define the dispute between the
parties. See Mendes v. Commissioner, supra.
B. The Legal Sufficiency of the Notice
Petitioner contests the sufficiency of the notice. For the
Secretary to issue a notice of deficiency, section 6212 requires
that he determine a deficiency, send notice of that deficiency to
the taxpayer’s last known address, include with that notice
notice of the taxpayer’s right to contact the local office of the
taxpayer advocate, and provide the taxpayer with contact
information for that office. Section 7522(a) provides that the
notice of deficiency “shall 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.” The section further provides: “An inadequate
description under the preceding sentence shall not invalidate
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