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While there were withheld taxes and payment credits, a balance is
due and owing with respect to each of the taxable years 1992
through 1996.
The 1997 tax return was filed on August 3, 1998. While
petitioner’s account was credited with some withholding tax, a
balance was reflected as due on the return. An additional tax
was assessed on February 28, 2000, based on an agreement by
petitioner. A balance remains due.
On January 3, 1999, petitioner filed amended returns for the
taxable years 1990, 1991, 1992, and 1993. Petitioner claimed a
casualty loss for 1990, which she sought to carry forward to the
taxable years 1991 through 1993.
On November 17, 1999, respondent notified petitioner of a
proposed disallowance of the claimed casualty loss. On December
13, 1999, respondent issued a letter to petitioner advising of
the right to an Appeals Office hearing with respect to the
disallowance. Petitioner requested a hearing before the Appeals
Office. By letter dated November 2, 2000, respondent’s Appeals
Office advised petitioner that the claim was disallowed on the
merits and further indicated as follows:
If you wish to bring suit or proceedings for the
recovery of any tax, penalties or other moneys for
which this disallowance notice is issued, you may do so
by filing such a suit with the United States District
Court having jurisdiction, or with the United States
Court of Federal Claims. The law permits you to do
this within 2 years from the mailing date of this
letter. However, if you signed a waiver of the notice
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