Kathryn Bernal - Page 12




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          not alleged that she did not receive the notices of deficiency in           
          sufficient time to timely petition, or that the notices of                  
          deficiency are otherwise invalid.  See Pietanza v. Commissioner,            
          92 T.C. 729, 735 (1989), affd. 935 F.2d 1282 (3d Cir. 1991).                
               Accordingly, we shall grant respondent’s motion to dismiss             
          this case for lack of jurisdiction with respect to the taxable              
          years 1993, 1994, 1995, and 1996.                                           
               To reflect the foregoing,                                              
                                             An order will be issued                  
                                        granting respondent’s motion to               
                                        dismiss for lack of jurisdiction              
                                        and to strike as to taxable years             
                                        1993, 1994, 1995, and 1996.                   

























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