"[T]he notice 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."
How later courts described this case
- "[T]he notice 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."
- looking at whether taxpayers were misled to determine adequacy of notice of deficiency
Written by the judges who cited it.
The opinion
SWAN, Circuit Judge
(concurring).
Accepting the majority opinion in Bogardus v. Commissioner, 88 F.(2d) 646 , as establishing the taxability of the payment in question, I concur.