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not mailed to petitioner’s last known address. On October 15,
2001, we granted respondent’s motion to dismiss as to 1989 and
1990 on the ground that respondent had not issued a notice of
deficiency or made any other determination that would confer
jurisdiction on the Court.
On January 14, 2002, petitioner filed a motion for
litigation and administrative costs. The motion states that
petitioner’s cost of litigating her claim was $8,985. Petitioner
states that she borrowed $8,800 from her parents to “maintain a
location and the ability to litigate”, and that she incurred $186
in postage, photocopying, and typewriter costs.
On January 14, 2002, the Court vacated its order of
dismissal for lack of jurisdiction so that the disposition of
petitioner’s motion for litigation and administrative costs would
be included in the decision entered in the case pursuant to Rule
232(f).
On March 4, 2002, the Court filed a letter from petitioner
as petitioner’s motion to restrain assessment and collection.
Petitioner’s motion states that she received notices of intent to
levy for 1993 and 1994 without having received notice that any
tax was due and owing. On March 21, 2002, petitioner filed a
first supplement restating much of what was in her original
motion to restrain assessment and collection, and on March 25,
2002, she filed a second supplement. The second supplement
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