Deborah F. Robinson - Page 13

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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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