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of law. Consequently, we shall grant that part of respondent’s
motion as moves for summary adjudication under Rule 121.
Background
The record establishes and/or the parties do not dispute the
following facts.2
Petitioner resided in Tulsa, Oklahoma, on the date
petitioner filed her petition in this case.
Petitioner failed to file her Federal income tax return for
1993. On January 18, 1996, respondent mailed a statutory notice
of deficiency to petitioner, in which he determined that
petitioner was liable for an income tax deficiency and additions
to tax for 1993. Petitioner received the notice of deficiency
but did not petition this Court with respect to the notice of
deficiency. Subsequently, respondent assessed the income tax
deficiency, additions to tax, and interest against petitioner on
July 22, 1996.
Petitioner also failed to file her Federal income tax return
for 1994. On October 22, 1996, respondent mailed a statutory
notice of deficiency to petitioner in which he determined that
petitioner was liable for an income tax deficiency and additions
to tax for 1994. Petitioner received the notice of deficiency
2The facts material to the Court’s disposition of the motion
for summary judgment are stated solely for purposes of deciding
the motion and are not findings of fact for this case. See
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.
17 F.3d 965 (7th Cir. 1994)
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