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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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