Read the following excerpt from a US court opinion:
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a notice “specifically stating the taxpayer’s liability and the basis for the liability;” a FPAA is “sufficient notice” of tax liability to allow the interest to start accruing again. Pl. Reply at 12-13 (citing I.R.C. § 5404(g)(1)(A); Treas. Reg. § 301.6404-4(a)(7)(ii)). In addition, either the issuance of the FPAA or the Government’s Answer commenced the “qualified offer period.” Pl. Reply at 13-15. Treasury Regulation § 301.7430-3(c)(3) treats a FPAA as a “notice of deficiency” that serves to start the “qualified offer period.” See Treas. Reg. § 301.7430-3(c)(3). For this reason, the United States Court of Appeals for the Fifth Circuit has held that a FPAA is the “functional equivalent of a notice of deficiency,” Sealy Power, Ltd. v. Comm’r, 46 F.3d 382, 385-85 (5th Cir. 1995) . Alternatively, the Government’s August 10,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that where notice of deficiency fails adequately to describe the basis on which the commissioner relies for his deficiency determination burden shifts to the commissioner to prove the accuracy of the deficiency determination
B. holding that a fpaa is the functional equivalent of a notice of deficiency because it serves to afford affected taxpayers that the commissioner has made a final administrative determination of their liability for particular tax years
C. holding that a prefiling notification letter from the internal revenue service was not a notice of deficiency and therefore the tax court had no jurisdiction over the taxpayers petition
D. holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice
E. holding that the statute of limitations began to run when the plaintiff first received notice of an alleged deficiency from the irs not when he received a final determination of tax liability
Reply with [A, B, C, D, E] only.