- 15 - 1978), affg. in part 66 T.C. 743 (1976) and 67 T.C. 176 (1976). In both Sanderling and Burford, the Commissioner issued a notice of deficiency covering an incorrect taxable period longer than was appropriate. In Burford, the notice covered the calendar year instead of a calendar quarter. In Sanderling, the Commissioner issued the notice based on a liquidation date that was later than the corporation’s actual liquidation date. Both courts noted in their analysis that the incorrect taxable period stated in the notice of deficiency fully encompassed the proper period. Sanderling, Inc. v. Commissioner, supra at 176; Burford v. Commissioner, supra at 99. We decline petitioner’s invitation to hold that the foregoing scenario presents the only situation where a notice of deficiency bearing an incorrect year would constitute a valid notice. Deriving such a meaning from Sanderling and Burford disregards additional observations by the courts. As part of their reasoning, both Burford and Sanderling also look at whether the taxpayer could be misled by the error in the notice. Sanderling, Inc. v. Commissioner, supra at 176; Burford v. Commissioner, supra at 99; Petitioner’s interpretation of Sanderling and Burford also ignores our most recent caselaw (cited above) involving typographical errors in notices of deficiency. The particularPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007