Jan Lister - Page 3




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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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