- 14 - (1951), and Columbia River Orchards, Inc. v. Commissioner, 15 T.C. 253 (1950), involved situations where the Commissioner actually determined deficiencies for the wrong taxable years. In Century Data Sys. Inc. and Atlas Oil, the Commissioner used fiscal years instead of the appropriate calendar years to calculate the deficiency. Similarly, in Columbia River Orchards, the deficiency was calculated and asserted for a short calendar year because the Commissioner had incorrectly believed the corporate taxpayer had liquidated. In these cases, the deficiency calculations “necessarily omitted items of income and deduction of the correct taxable year and * * *[or had] included other items which properly belong in another taxable year.” Century Data Sys. Inc. v. Commissioner, supra at 534-535. In the case before us, respondent made calculations and determined a deficiency for the correct taxable year, calendar year 1996. The distinguishable facts in Century Data Sys. Inc., Atlas Oil, and Columbia River Orchards do not require us to reach the same result we reached in those cases as petitioner would like. We are likewise not persuaded by petitioner’s reliance on comments made in Burford v. Commissioner, 76 T.C. 96 (1981), affd. without published opinion 786 F.2d 1151 (4th Cir. 1986), and Sanderling, Inc. v. Commissioner, 571 F.2d 174 (3d Cir.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007