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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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