Evelyn Perkins - Page 4




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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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