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shall grant respondent’s motion.2
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Chicago, Illinois, at the time she
filed the petition in this case.
On November 3, 1993, and February 3, 1993, respectively,
respondent issued to petitioner notices of deficiency with
respect to her taxable years 1988 and 1989, which she received.
In the notice of deficiency (notice) relating to petitioner’s
taxable year 1988, respondent determined a deficiency in, and
additions under sections 6651(a)(1) and 6653(a)(1)3 to, peti-
tioner’s Federal income tax (tax) for that year in the respective
amounts of $2,368, $504, and $118. In the notice relating to
petitioner’s taxable year 1989, respondent determined a defi-
ciency in petitioner’s tax for that year of $3,217.
Petitioner did not file a petition in the Court with respect
2Respondent concedes in respondent’s motion that “the col-
lection actions taken against petitioner, as they relate to
petitioner’s income tax liability for tax year 1993 are im-
proper.” Respondent further states that “Respondent is in the
process of abating the assessment of petitioner’s income tax
liability and additions to tax for taxable year 1993.” In light
of respondent’s concession with respect to petitioner’s taxable
year 1993, we shall address the collection actions at issue only
with respect to petitioner’s taxable years 1988 and 1989.
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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