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refer collectively to respondent’s motion for summary judgment
and respondent’s motion for a penalty as respondent’s motions.)
We shall grant respondent’s motions.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Garner, North Carolina, at the time
she filed the petition in this case.
On February 11, 2002, respondent issued to petitioner a
notice of deficiency (notice of deficiency) with respect to her
taxable years 1997, 1998, and 1999. In that notice of defi-
ciency, respondent determined a deficiency in, and additions to,
petitioner’s Federal income tax (tax), as follows:
Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6651(a)(2) Sec. 6654(a)
*
1997 $14,644 $10,471 $771
*
1998 5,842 4,162 262
*
1999 6,759 4,801 319
*In the notice of deficiency, respondent stated:
The amount of the addition to tax cannot be determined
at this time, and an addition to tax of 0.5 percent
will be imposed for each additional month, or fraction
thereof, of nonpayment, up to 22.5 percent as provided
by section 6651(a)(2) of the Internal Revenue Code for
the taxable years ended December 31, 1997; December 31,
1998; and December 31, 1999.
Petitioner did not file a petition with the Court with
1(...continued)
(Code) in effect at all relevant times. All Rule references are
to the Tax Court Rules of Practice and Procedure.
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