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Respondent’s counsel appeared and presented argument in support
of the pending motion. In particular, counsel introduced into
the record copies of petitioner’s above-described income tax
returns for 1999 and 2000.
Following the hearing, the Court issued an Order stating
that it would defer ruling on respondent’s motion to dismiss for
60 days in order to afford the parties an opportunity to try to
resolve administratively the substantive issues related to
petitioner’s tax liability for the taxable year in issue. The
Court also directed that a report be filed by June 24, 2002,
advising of the then present status of this matter.
On June 24, 2002, respondent filed a Status Report. In the
report, respondent stated that a letter had been sent to
petitioner requesting information that might have permitted the
parties to resolve administratively the substantive issues in
this case; respondent also stated that no response had been
received from petitioner, nor had the letter been returned to
respondent by the Postal Service.
Discussion
This Court's jurisdiction to redetermine a deficiency
depends upon the issuance of a valid notice of deficiency and a
timely filed petition. See Rule 13(a), (c); Monge v.
Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v.
Commissioner, 90 T.C. 142, 147 (1988). Section 6212(a) expressly
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