Estate of Silvio Ravetti, Deceased, Donna Irene Logan v. Commissioner, Internal Revenue Service

38 F.3d 1218 74 A.F.T.R.2d 94 -6736 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. ESTATE OF Silvio RAVETTI, Deceased, Donna Irene Logan, Executrix, Petitioner Appellant, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent Appellee. No. 93-70851. United States Court of Appeals, Ninth Circuit. Submitted Oct. 3, 1994. * Decided Oct. 11, 1994. Before: GOODWIN, O'SCANNLAIN and KLEINFELD, Circuit Judges. 1 MEMORANDUM ** 2 We affirm the Tax Court summary judgment. 3 The Estate argues that the notice of deficiency was inadequate under Scar v. Commissioner, 814 F.2d 1363, 1367 (9th Cir.1987). That is incorrect. The notice sufficed, under our reading of Scar in Kantor v. Commissioner, 998 F.2d 1514, 1521 (9th Cir.1993). The Scar notice showed on its face that the IRS had not really determined the amount of the deficiency and had issued the notice without even looking at the taxpayer's return. The deficiency notice was based upon a mining partnership which had nothing to do with…