Argued and Submitted April 11, 2001 — San Francisco, California.
BEEZER, Circuit Judge:
Appellant Win H. Emert ("Emert") challenges the tax court's computations under Tax Court Rule 155. He argues that a 26 U.S.C. § 481 adjustment was improper because the IRS failed to describe § 481 as a basis for tax due in its notice of deficiency as required by 26 U.S.C. § 7522. We have jurisdiction pursuant to 26 U.S.C. § 7482 and AFFIRM.
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