Court of Appeals for the Eleventh Circuit April 29, 1986, 85-8734 (Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal Revenue)

KRAVITCH, Circuit Judge:

This appeal requires us to decide whether a letter sent by the IRS is a deficiency determination and notice sufficient to trigger the jurisdiction of the United States Tax Court within the meaning of I.R.C. §§ 6212(a) and 6213(a).