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On April 19, 2001, petitioner filed a petition for the 1987
through 1994 tax years.3 The Court waived the filing fee. On
May 7, 2001, petitioner filed a motion to dismiss for lack of
jurisdiction for the tax years 1987 through 1994. Petitioner’s
motion alleged that the notices of deficiency were not mailed to
petitioner’s last known address, and that respondent had reason
to know petitioner changed her address because of Forms W-2, Wage
and Tax Statement, filed by petitioner’s former employers. The
petition went on to state that petitioner was unable to work
after her last job in 1996, until after approximately November
2000, when she applied for a position with ETT Gaming. According
to petitioner, she was not hired by ETT Gaming because of the
Federal tax lien, and the lien had prevented her from securing
employment with other employers.
The Court directed respondent to respond to petitioner’s
motion by June 4, 2001. On June 4, 2001, respondent filed a
motion for extension of time to respond, stating that more time
was needed for the investigation. The Court granted the
extension and ordered respondent to respond by August 4, 2001.
2(...continued)
liabilities than those prepared by respondent. For example,
respondent’s 1988 return shows a tax of $3,627 while petitioner’s
return shows $195.
3The petition was with respect to the years 1987-94
inclusive. Respondent’s assessments are with respect to 1987,
1988, 1991, 1992, 1993, and 1994 years.
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