Yvonne Thomas - Page 6

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          should be treated as a mere “math error” which, under the above             
          IRM provision, should be treated as an administrative adjustment            
          automatically in issue under section 6330(c)(1) and (c)(3)(C).              
               Further, petitioner refers to the mandate of the Americans             
          With Disabilities Act of 1990 (ADA), Pub. L. 101-336, 104 Stat.             
          327, currently codified as 42 U.S.C. secs. 12101-12213 (2000), to           
          the general effect that disabled persons be given equal access to           
          governmental agencies, and petitioner argues that because she has           
          medical disabilities, the ADA overrides the period of limitations           
          of section 6213(a) and the jurisdictional limitation of section             
          6330(c)(2)(B), and she should be allowed to raise an issue as to            
          her correct Federal income tax liability.                                   
               At the March 26, 2007, Court hearing on the instant motions            
          in limine, petitioner’s counsel claimed to have in his possession           
          corrected brokerage account information showing that all 2002               
          stock sales that properly are to be charged to petitioner                   
          resulted in a net loss.                                                     

               We briefly discuss our reasons for rejecting petitioner’s              
          various arguments and for granting respondent’s motion in limine.           
               Upon receipt of the notice of deficiency petitioner filed a            
          police report.  Obviously, petitioner could have chosen in                  
          addition, or in lieu thereof, to file a Tax Court petition.                 
          Petitioner made that choice.  Petitioner’s explanation for not              

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