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assessment or collection of a deficiency if respondent's
collection efforts relate to a taxable year over which we have no
jurisdiction. Schlosser v. Commissioner, 94 T.C. 816, 823
(1990); Kamholz v. Commissioner, 94 T.C. 11, 15 (1990).
Because we lack jurisdiction over all 4 of the taxable years
that petitioner wishes to place in issue, we are constrained to
deny petitioner's motion to restrain.
Conclusion
In view of the foregoing, we hold that the notices of
deficiency for 1988, 1989, and 1991 were sent to petitioner at
her last known address.11 We also hold that no valid notice of
deficiency for 1990 was sent to petitioner.
To give effect to the foregoing,
An order will be entered
denying petitioner's motion to
restrain assessment or
collection, and granting
respondent's motion to dismiss
for lack of jurisdiction.
11 Although petitioner cannot pursue her case in this
Court, she is not without a remedy. In short, petitioner may pay
the tax, file a claim for refund with the Internal Revenue
Service, and if the claim is denied, sue for a refund in the
Federal District Court or the U.S. Court of Federal Claims. See
McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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