Norma Neiman - Page 5

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                  Petitioner asks this Court to consider her difficult                                 
            physical, emotional, and financial circumstances.  As we                                   
            indicated at the conclusion of the trial of this case, our                                 
            jurisdiction, as defined by Congress, is limited to a                                      
            determination of the correct tax liability.  We again recommend                            
            that petitioner communicate with appropriate persons within the                            
            Internal Revenue Service to seek advice and assistance with                                
            respect to payment of the tax liability.                                                   
                  To reflect the foregoing,                                                            
                                                      Decision will be entered                         
                                                for respondent.                                        



























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