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ling in the instant case.
Before addressing each of the issues remaining for decision,
we note that we have considered all of petitioner’s contentions
and arguments that are not discussed herein, and we find them to
be baseless, without merit, and/or irrelevant.
Period of Limitations
Although not pled in the petition, petitioner argues that
the respective periods of limitations under section 6501 with
respect to her taxable years 1989 through 1992 have expired.2
That is because, according to petitioner, she timely filed her
tax returns for those years, and the notices with respect to
those years were not issued until April 10, 1998. We reject
petitioner’s contention.
Except for petitioner’s self-serving, uncorroborated, and
conclusory testimony that she timely filed her tax returns for
the years 1989 through 1992, the record is devoid of evidence
supporting petitioner’s position under section 6501. In fact,
2Although petitioner also argues on brief about her taxable
year 1993, petitioner conceded at trial that she did not file a
tax return for that year. Therefore, we find that petitioner
also conceded that the period of limitations under sec. 6501 with
respect to petitioner’s taxable year 1993 has not expired.
Petitioner also conceded at trial that she is liable for the
addition to tax under sec. 6651(a)(1) for 1993. Assuming arguen-
do that petitioner had not made the foregoing concessions with
respect to her taxable year 1993, on the record before us, we
would nonetheless find that petitioner has failed to establish
that the period of limitations under sec. 6501 with respect to
1993 has expired and that she is not liable for the addition to
tax under sec. 6651(a)(1) for that year.
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