Laurel Ann Curtis - Page 15




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          II.  Discussion                                                             
               Petitioner failed to file income tax returns for the years             
          in question, and respondent was obliged to look to other sources            
          to determine whether petitioner owed any income taxes.                      
          Respondent determined that petitioner did owe taxes and issued              
          the notices of deficiency.  Petitioner assigned only the                    
          following error:  “more income than I earned was attributed to me           
          in each of * * * [the years in question] & far less expense than            
          I incurred & am allowed to deduct was given in each of those                
          years.”  Petitioner averred no specific facts in support of her             
          assignment of error and did not claim explicitly that                       
          respondent’s determinations were arbitrary, erroneous, or                   
          unsupported by minimal evidence.  Petitioner attached to the                
          petition the first page of each of the notices of deficiency.               
          Those first pages show, among other things, the amount of the               
          deficiency and penalties for each year covered by that particular           
          notice.  Each first page clearly instructs the recipient to                 
          include with any petition to the Tax Court “a copy of all                   
          statements and schedules you received with this letter”.  Rule              
          34(b)(8) likewise requires such statements and schedules to be              
          attached to a petition.  Petitioner failed to include any                   
          statement or schedule with the petition.  Since petitioner                  
          attached to her posttrial memorandum as Exhibit A two pages that            
          accompanied the notice of deficiency for 1992 and 1993, we know             






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