Contents
(c)
(1)If the Secretary has mailed to the taxpayer a notice of deficiency as provided in subsection (a), and the taxpayer files a petition with the Tax Court within the time prescribed in section 6213(a), the Secretary shall have no right to determine any additional deficiency of income tax for the same taxable year, of gift tax for the same calendar year, of estate tax in respect of the taxable estate of the same decedent, of chapter 41 tax for the same taxable year, of chapter 43 tax for the same taxable year, of chapter 44 tax for the same taxable year, of section 4940 tax for the same taxable year, or of chapter 42 tax, (other than under section 4940) with respect to any act (or failure to act) to which such petition relates, except in the case of fraud, and except as provided in section 6214(a) (relating to assertion of greater deficiencies before the Tax Court), in section 6213(b)(1) (relating to mathematical or clerical errors), in section 6851 or 6852 (relating to termination assessments), or in section 6861(c) (relating to the making of jeopardy assessments).
(2)For assessment as a deficiency notwithstanding the prohibition of further deficiency letters, in the case of—
(A)Deficiency attributable to change of treatment with respect to itemized deductions, see section 63(e)(3).
(B)Deficiency attributable to gain on involuntary conversion, see section 1033(a)(2)(C) and (D).
(C)Deficiency attributable to activities not engaged in for profit, see section 183(e)(4).
For provisions allowing determination of tax in title 11 cases, see section 505(a) of title 11 of the United States Code.
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