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ground T.C. Memo. 1990-380; Clapp v. Commissioner, 875 F.2d 1396,
1402 (9th Cir. 1989).
Those circumstances are not present in this case. Unlike
the notice of deficiency in Scar, the notice of deficiency in
this matter clearly disallowed amounts claimed on petitioners’
2001 and 2002 amended returns: the notice disallowed the amounts
of $990,700 and $165,116 claimed as reductions to Mr. Wadsworth’s
distributive share of income from Gold Coast for 2001 and 2002,
respectively. Although the notice of deficiency does not
identify Gold Coast by name, it does determine deficiencies of
$147,708 and $56,958 for 2001 and 2002 respectively. Those
amounts are identical to the refunds claimed on petitioners’ 2001
and 2002 amended returns. The notice of deficiency in this
matter therefore did not reveal on its face that respondent
failed to make a determination with regard to petitioners’ 2001
and 2002 tax liabilities. Consequently, we reject petitioners’
argument that the notice of deficiency cannot serve as the basis
of our jurisdiction because it is not the product of an actual
determination of respondent.
Petitioners also argue that this Court lacks jurisdiction to
decide whether they received income from Gold Coast because Gold
Coast is subject to the unified partnership procedures of
sections 6221 through 6233. See Tax Equity and Fiscal
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