- 12 - consideration along with the surrounding circumstances, we must decide in this case whether petitioner could have been reasonably confused or misled as to the taxable year involved. The facts and circumstances in this case lead us to conclude that the notice of deficiency is valid because it contained enough information such that petitioner could not reasonably be deceived as to the taxable period involved (calendar year 1996). Both the explanation of changes and the additional attached schedule contain figures that are directly traceable to petitioner’s 1996 gift tax return, including the value of the gifts as shown on the return and the amount of tax previously paid. The additional schedule, though it does not indicate any dates for the taxable period involved, details the three gifts that petitioner made in 1996. This schedule lists each donee of the 1996 gifts, the percentage of the Upchurch Family Limited Partnership given to each donee, the value of the gifts as reflected on petitioner’s 1996 gift tax return, and the corrected values of each gift, which also match the examiner’s report for 1996. The cover page of the notice and attachments asserted the exact same amount of deficiency as was proposed in the previously sent 30-day letter for calendar year 1996. The adjustments and computations in the attached explanation of tax changes are also identical to those in the examiner’s report for calendar year 1996.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007