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In the portion of her brief headed "ARGUMENT", petitioner
elaborates upon her position that she is not liable for any of
the additions to tax under sections 6651(f) and 6653(b). How-
ever, petitioner provides no further explanation in that portion
of her brief about her claim that the respective periods of
limitations for the years at issue have expired. We nonetheless
shall briefly address that contention.
The expiration of the period of limitations is an affirma-
tive defense which petitioner raised in the petition and on brief
and on which she has the burden of proof. See Rule 142(a);
United States v. Gurley, 415 F.2d 144, 147 (5th Cir. 1969);
Amesbury Apartments, Ltd. v. Commissioner, 95 T.C. 227, 240
(1990). Petitioner must make a prima facie case establishing
that she filed her return for each of the years at issue, that
the period of limitations for each such year has expired, and
that respondent mailed the notices to her after the expiration of
each such period. See Miami Purchasing Serv. Corp., Inc. v. Com-
missioner, 76 T.C. 818, 823 (1981); Robinson v. Commissioner, 57
T.C. 735, 737 (1972). If petitioner were to make such a showing,
the burden of going forward with the evidence would shift to
respondent, and respondent would have to introduce evidence
establishing that the respective periods of limitations for the
years at issue have not expired. See Amesbury Apartments, Ltd.
v. Commissioner, supra at 241; Adler v. Commissioner, 85 T.C.
535, 540 (1985). If respondent were to make such a showing, the
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