Kathryn Bernal - Page 2




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               deficiency, we shall grant R’s motion to dismiss and                   
               strike so much of the petition as seeks review of the                  
               denial of the request for relief made pursuant to sec.                 
               66(c), I.R.C.                                                          

               Kathryn Bernal, pro se.                                                
               David Jojola, for respondent.                                          

                                       OPINION                                        
               DAWSON, Judge:  This case was assigned to Chief Special                
          Trial Judge Peter J. Panuthos, pursuant to the provisions of                
          section 7443A(b)(5) and Rules 180, 181, and 183.1  The Court                
          agrees with and adopts the opinion of the Chief Special Trial               
          Judge, which is set forth below.                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PANUTHOS, Chief Special Trial Judge:  This matter is before            
          the Court on respondent’s motion to dismiss for lack of                     
          jurisdiction and to strike as to the taxable years 1993, 1994,              
          1995, and 1996.  As explained in detail below, we shall grant               
          respondent’s motion to dismiss.2                                            



               1  Section references are to the Internal Revenue Code, and            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               2  The petition places in dispute the taxable year 1992 as             
          well as the taxable years 1993 through 1996.  Respondent does not           
          seek dismissal with respect to 1992.  Thus, the order will strike           
          references to all tax years other than 1992.  As the record is              
          incomplete, we do not address jurisdictional issues with respect            
          to 1992 in this opinion.                                                    





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