Petaluma FX Partners, LLC, Ronald Scott Vanderbeek, A Partner Other Than The Tax Matters Partner - Page 6

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          another taxable year.”  Century Data Sys., Inc. v. Commissioner,            
          supra at 534-535.  Thus, if the Commissioner is without authority           
          to issue a notice for less than a taxpayer’s full taxable year,             
          we are without authority to review the adjustments therein.  See            
          id. at 536, 537; Schick v. Commissioner, 45 T.C. 368, 373 (1966).           
               At the same time, however, we have held that an error in a             
          notice of deficiency concerning the taxable period at issue will            
          not invalidate the notice if the taxpayer was not misled by the             
          error.  St. Paul Bottling Co. v. Commissioner, 34 T.C. 1137                 
          (1960); see also, e.g., Anderten v. Commissioner, T.C. Memo.                
          1993-2 (references to wrong taxable year in explanation did not             
          invalidate notice); Erickson v. Commissioner, T.C. Memo. 1991-97            
          (when taxpayer receives single document including a cover letter            
          and explanatory statements, we look to the entire document to               
          determine whether the taxpayer could have been misled).  In St.             
          Paul Bottling Co., the Commissioner issued a notice of deficiency           
          stating that the Commissioner had determined deficiencies for the           
          taxable years 1952, 1953, and 1954.  The attached explanation               
          however, made clear that the Commissioner had in fact determined            
          deficiencies for the 1956, 1957, and 1958 tax years.  We held               
          that it was proper to ignore the error where the taxpayer was not           
          misled.  Thus, a notice of deficiency (or FPAA) containing errors           
          with respect to the taxable year at issue may still confer                  
          jurisdiction upon this Court where the taxpayer reasonably could            

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