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(b). The taxpayer will file his 2000, 2001 and 2002
income tax returns with the Internal Revenue Service
Hartford, Connecticut Office reflecting the correct
information.
(c). The penalties should be abated due to reasonable
causes as discussed in Form 12153, copy enclosed.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We
conclude that there are no genuine issues of material fact
regarding the questions raised in respondent’s motion.
In the petition, petitioner alleged that the 2000 and 2001
notice and the 2002 notice are wrong and that the additions to
tax for those years “should be abated”.4
We first address petitioner’s allegation in the petition
that the Court should abate the respective additions to tax for
his taxable years 2000, 2001, and 2002. Although not altogether
clear, petitioner appears to be requesting the Court to review
4In the petition, petitioner refers to the respective no-
tices of intent to levy that respondent issued with respect to
petitioner’s taxable years 2000 and 2001 and 2002. Petitioner’s
authorized representative did not file timely petitioner’s Form
12153 with respect to those notices, see sec. 6330(a)(2) and
(3)(B) and (b), and the notice of determination makes no determi-
nation with respect to those notices. We conclude that we do not
have jurisdiction to consider petitioner’s arguments with respect
to the notices of intent to levy. See Offiler v. Commissioner,
114 T.C. 492, 498 (2000).
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