id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-3506	Lederman, Leandra	Are There Procedural Deficiencies in Tax Fraud Cases?: A Reply to Professor Schoenfeld	2001	30	.pdf	application/pdf	15266	918	61	Code section 7522, enacted subsequent to the decision in Greenberg's Express, requires specificity in IRS notices, including notices of deficiency. The notice of deficiency also provides the taxpayer with a ticket to the Tax Court; Tax Court subject-matterjurisdiction over tax deficiency cases requires both a notice of deficiency and a timely responsive petition (generally one that is filed within ninety days ofthe date the notice ofdeficiency was mailed).^^	cache/inlawrev-3506.pdf	txt/inlawrev-3506.txt