Staggs

MEMORANDUM **

Dannie and Rhonda Staggs appeal the Tax Court’s denial of their motion to dismiss for lack of jurisdiction their action to redetermine their income tax deficiency and that of the two trusts to which the Staggs had assigned some of their income. The Staggs also appeal the Tax Court’s decision to grant the Internal Revenue Service’s motion for summary judgment. The Tax Court concluded that a notice of deficiency and a timely appeal were the only prerequisites to its exercise of jurisdiction, and that no dispute remained regarding the amount of income tax deficiency. We affirm.

I

The Tax Court has jurisdiction to redetermine a deficiency when the IRS has issued a valid notice and the taxpayer files a timely petition for redetermination. 26 U.S.C. § 7442 ; Meserve Drilling Partners v. Comm’r, 152 F.3d 1181, 1183 (9th Cir.1998). There is “no particular form ... for a valid notice of deficiency.” Me-serve, 152 F.3d at 1183 . However, the notice must, at a minimum, “advise the taxpayer that his tax return is deficient for a particular year and specify the amount of the deficiency or provide the information necessary to compute the deficiency.” Abrams v. Comm’r, 814 F.2d…