Nick A. Shubin - Page 5

                                         -5-                                          
               We also conclude that we lack jurisdiction as to the                   
          remaining years.  Respondent has not issued to petitioner a                 
          notice of deficiency as to any of those years.  Nor does there              
          appear to be an alternative basis on which to predicate                     
          jurisdiction.                                                               
               On the basis of the record before us and on the analysis               
          above, we conclude that we lack jurisdiction in this case, and we           
          shall grant respondent’s motion.                                            
               To reflect the foregoing,                                              
                                                  An appropriate order                
                                             granting respondent’s motion             
                                             to dismiss for lack of                   
                                             jurisdiction will be entered.            
























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