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and interest] [sic] on * * * 1995 & 1998 taxes, less the $3449
* * * already paid and not the $82,874.19 the I.R.S. claims”.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and the decision may be rendered
as a matter of law. Rule 121(b); Sundstrand Corp. v. Commis-
sioner, 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.
Petitioner received from respondent a notice of deficiency
with respect to his taxable years 1995 and 1998. Petitioner
submitted a document with respect to that notice that the Court
had filed as a petition and that commenced the case at docket No.
14560-02. However, petitioner failed to respond to the Court’s
September 16, 2002 Order in the case at docket No. 14560-02, in
which the Court directed petitioner to file a proper amended
petition and to pay a filing fee on or before November 15, 2002.
As a result, on March 4, 2003, the Court entered an order of
dismissal for lack of jurisdiction in that case. We conclude
that petitioner may not dispute the respective underlying tax
liabilities for his taxable years for 1995 and 1998.
Where, as is the case here, the validity of the underlying
tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of Internal Revenue
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