§62121

3 [*3] MEMORANDUM FINDINGS OF FACT AND OPINION GUSTAFSON, Judge: In these consolidated cases, the Internal Revenue Service (“IRS”) issued pursuant to section 62121 statutory notices of deficiency (“NOD”) to petitioner Alex Deitch and to married petitioners Jonathan and Susan Barry2 on July 14, 2017.

MEMORANDUM FINDINGS OF FACT AND OPINION GUSTAFSON, Judge: The Internal Revenue Service (“IRS”) issued to petitioner, Tracy Renee Valentine, a statutory notice of deficiency (“SNOD”) pursuant to section 62121 on February 19, 2019, determining for the year 2016 a deficiency in her federal income tax in the amount of $11,034 (and additions to tax).

("Uniband"), pursuant to section 62121 on November 28, 2005, the Internal Revenue Service ("IRS") determined income tax deficiencies of$220,851 for 1996, $754,758 for 1997, and $308,498 for 1998.

Halata a statutory notice ofdeficiency pursuant to section 62121 showing the 'All references to sections are to sections ofthe Internal Revenue Code.

i MEMORANDUM OPINION GUSTAFSON, Judge : The Internal Revenue Service (IRS) issued to petitioner Joanna Del,Valle Vllafane a statutory notice of deficiency pursuant to section 62121 for the year 2006, showing 'Unless otherwise indicated,' all citations of sections refer to the Internal Revenue Code of 1986 (26 U .S .C.), as amended, and all citations of Rules refer to the Tax Court Rules of Practice and Procedure .