- 6 - 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. Discussion 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 notPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007