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F.2d 1379, 1381-1382 (9th Cir. 1988) (affg. this Court’s denial
of the taxpayers’ motions to dismiss for lack of jurisdiction).
Thus, there is no relationship between the Commissioner’s
preparation or nonpreparation of substitute returns under section
6020(b) and his right to issue a notice of deficiency. See also
Geiselman v. United States, 961 F.2d 1, 3 (1st Cir. 1992).
Moreover, there is no requirement that a notice of deficiency be
issued in any particular form. The purpose of a notice of
deficiency “is only to advise the person who is to pay the
deficiency that the Commissioner means to assess him; anything
that does this unequivocally is good enough”. Olsen v.
Helvering, 88 F.2d 650, 651 (2d Cir. 1937); see also, e.g.,
Kellogg v. Commissioner, 88 T.C. 167, 171 (1987) (“No particular
form [for a notice of deficiency] is required”); Foster v.
Commissioner, 80 T.C. 34, 229 (1983) (all that is required “is
that the notice fulfill its purpose of providing formal
notification that a deficiency in tax has been determined”),
affd. in part and vacated in part 756 F.2d 1430 (9th Cir. 1985);
Jarvis v. Commissioner, 78 T.C. 646, 655 (1982) (“The Internal
Revenue Code * * * in neither section 6212(a) nor elsewhere
prescribes the form of a notice or the specifics to be contained
therein.”). The deficiency notices issued to petitioner for the
years in issue clearly meet the above-described requirements and
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