No. 90-4343.

932 F.2d 1128 (1991)

Ramon PORTILLO and Dolores Portillo, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Fifth Circuit.

June 11, 1991.

Attorney(s) appearing for the Case

David Leeper, Leeper & Leeper, El Paso, Tex., for petitioners.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Tax Litigation Div., Elizabeth Wickstrom, Gary R. Allen, Chief, Richard Farber, Appellate Sec., Tax Div., Dept. of Justice, Shirley D. Peterson, Asst. Atty. Gen., Washington, D.C., for respondent.

Before GOLDBERG, JOLLY and WIENER, Circuit Judges.

GOLDBERG, Circuit Judge:

Ramon Portillo appeals from the Tax Court's rejection of his challenge to a notice of deficiency from the Internal Revenue Service (the "I.R.S."). Portillo initially argues that the simple computerized matching of Portillo's employer's Form 1099 with Portillo's Form 1040 was not a "determination" as required by section 6212(a) of the Internal Revenue Code (the "Code"). We reject this argument, finding that the I.R.S. adequately linked Portillo...

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