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years in dispute. InverWorld, Ltd. v. Commissioner, 98 T.C. 70,
86 (1992), affd. 979 F.2d 868 (D.C. Cir. 1992). The petition
clearly conformed to all three requirements.
Petitioner insists that a separate notice of deficiency must
be attached with respect to each taxpayer involved in a
deficiency case. In support of his position, petitioner
mistakenly relies on cases in which the petitions did not list
all of the taxpayers’ names or all of the taxable years at issue.
See Normac, Inc. v. Commissioner, supra; O’Neil v. Commissioner,
supra; Estate of DuPuy v. Commissioner, 48 T.C. 918 (1967). In
this case, the petition that Mr. Berg filed listed both
petitioner and his former wife as petitioners and included, as an
attachment, a copy of the notice of deficiency issued with
respect to the 1980 joint Federal income tax return of petitioner
and his former wife.
Although this Court ultimately dismissed the petition in
Martin I for other jurisdictional reasons, Mr. Berg’s failure to
attach the notice did not invalidate the petition with respect to
petitioner and did not deprive us of jurisdiction. Consequently,
the filing of the petition placed a proceeding with respect to
petitioner’s 1980 income tax deficiency on our docket and
suspended the limitations period.
II. Installment Agreement Alternative
For the first time on brief, petitioner argues in the
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