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he alleges that petitioner instituted this proceeding primarily
for delay and her position is frivolous and groundless. By order
dated November 27, 2002, we directed petitioner to file a
response to respondent’s motion on or before December 27, 2002.
Petitioner’s response, which we received on December 18, 2002,
and filed as of that date, merely asserts that she is unable to
pay and appears to maintain that respondent owes her money.
Petitioner, however, did not support her contentions with any
documentation of her alleged inability to pay or of her
entitlement to a refund.
Discussion
I. Jurisdiction
Respondent’s notice of determination addressed only
respondent’s proposed levy action with respect to the taxable
years 1993 and 1994. Petitioner’s original petition referenced
only 1993 and 1994. In her amended petition, however, petitioner
identified the periods at issue as 1993 through the present. In
order to avoid any confusion regarding the periods at issue, we
consider, on our own initiative, our jurisdiction over years
other than 1993 and 1994.
It is well settled that questions of jurisdiction may be
raised by either party or the Court at any stage of a proceeding.
Moorhous v. Commissioner, 116 T.C. 263, 272 (2001) (citing Smith
v. Commissioner, 96 T.C. 10, 13-14 (1991)). Our jurisdiction
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