## Facts

- Doris L. Rickman died on October 24, 1990; her husband, James R. Rickman, died five days earlier.
- Their daughter, Doris K. (“Kaye”) Rickman, served as executrix for both estates.
- The executrix filed gift tax returns (Forms 709) for each spouse and estate tax returns (Forms 706) for each estate.
- James Rickman’s estate tax return reported several parcels of real property, including a parcel at 96 Golfview Drive valued at $47,000 based on an appraisal.
- The IRS issued an estate-tax notice of deficiency to Doris Rickman’s estate asserting more than $190,000 in additional federal estate tax.
- The notice correctly identified the decedent and her Social Security number and stated that the IRS had determined a deficiency.
- The notice referenced “Exhibit A” and “Exhibit B” as attachments, but the estate did not receive the exhibits.
- The estate asserted the notice contained errors and inconsistencies and argued the IRS failed to provide a valuation-explanation statement under I.R.C. § 7517 for valuation increases (including increasing the 96 Golfview Drive parcel to $61,000).

## Issues

1. Whether the Tax Court lacked jurisdiction because the notice of deficiency was invalid under I.R.C. § 6212(a) due to missing exhibits, alleged errors, and failure to provide a § 7517 valuation explanation.
2. Whether the notice was invalid under the rationale of Scar v. Commissioner because it allegedly failed to reflect an actual deficiency determination based on the estate’s return and circumstances.

## Decision

- The Tax Court held the notice of deficiency was valid under I.R.C. § 6212(a).
- Missing exhibits and alleged computational or clerical errors did not negate the existence of a deficiency determination and were not jurisdictional defects.
- Any failure to provide a valuation statement under I.R.C. § 7517 did not invalidate the notice or deprive the court of jurisdiction.
- Scar was distinguished because the notice here was tied to the taxpayer and the return, rather than facially unrelated to the taxpayer’s situation.
- The estate’s motion to dismiss for lack of jurisdiction (as amended) and motion to strike were denied.

## Legal Principles

- A deficiency notice is jurisdictionally sufficient if it fairly advises the taxpayer that the Commissioner has determined a deficiency for a specified tax and period, even if imperfectly drafted.
- Errors, omissions, or missing attachments in a deficiency notice generally affect the merits (amount or correctness of the deficiency), not the court’s jurisdiction.
- Scar’s invalid-notice rule is limited to situations where the notice, on its face, shows no determination regarding the taxpayer’s own liability.
- Procedural disclosure requirements concerning valuation explanations (including I.R.C. § 7517) are not part of the jurisdictional prerequisites for a valid notice under I.R.C. § 6212(a).

## Conclusion

The Tax Court retained jurisdiction because the notice identified the taxpayer and reflected an actual estate-tax deficiency determination; missing exhibits, alleged mistakes, and the asserted absence of a § 7517 valuation explanation did not render the notice invalid.


Estate of Rickman v. Comm’r, 70 T.C.M. (CCH) 1335 (1995)