John O. Green - Page 6




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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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