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petitioner’s own unreasonable conduct, the failure to file
returns or to otherwise notify respondent of any address changes,
and respondent’s conduct throughout the course of the
administrative proceeding, which we find was reasonable.
Petitioner states that she “had no knowledge of any taxes
owed and IRS did nothing to inform [her] of any taxes owed.” It
bears repeating that our scheme of taxation is premised on “self-
assessment” through the filing of returns, Sloan v. Commissioner,
102 T.C. 137, 146 (1994), affd. 53 F.3d 799 (7th Cir. 1995), and
it is the taxpayer’s obligation to inform the Commissioner of
taxes owed. Petitioner emphasizes that the Forms W-2 filed by
her former employers had the correct addresses. It therefore
follows that petitioner received the Forms W-2 and that
petitioner knew or should have known she was required to file
returns. By failing to file returns, as the law requires her to
do, or to otherwise notify respondent of her address changes,
petitioner bears much of the responsibility for not having
received the notices of deficiency.
Respondent acted reasonably when petitioner brought to his
attention that she had not received the notices of deficiency.
When petitioner contacted the Taxpayer Advocate Service in
December 2000, the period of limitations on assessment had not
started to run because petitioner had not filed returns. Sec.
6501(c)(3). Accordingly, respondent could have reissued the
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