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exhibit to his petition a copy of the notice for 1981. In
contrast, the taxpayer did not mention the taxable year 1980 in
his petition, nor did the taxpayer attach a copy of the notice
for 1980. Subsequently, the taxpayer moved to amend his petition
to include the taxable year 1980. The Court ultimately concluded
that jurisdiction was lacking as to the taxable year 1980 and
dismissed the case as to that year because the petition failed to
put that year into issue, and the taxpayer's motion for leave to
amend the petition was filed more than 90 days after the notice
of deficiency for 1980 was issued.
Although petitioner admits that he "inadvertently" failed to
include the taxable year 1992 in the Petition, petitioner argues
that such failure is principally attributable to "confusion"
created by the issuance of two notices of deficiency and by
respondent's allegedly stapling the two notices together.3
However, we need not assign or apportion any fault related to
petitioner's failure to include the taxable year 1992 in the
Petition, because neither estoppel nor other equitable
considerations afford any basis for us to assume jurisdiction as
to a taxable year in the absence of a timely filed petition as to
3 As previously stated, a complete copy of the notice of
deficiency for 1993 and 1994 was attached as an exhibit to the
Petition. If the notice for 1992 was stapled to the notice for
1993 and 1994, we fail to understand how petitioner could have
attached the latter, but not the former, as an exhibit to the
Petition.
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