COLLINS, District Judge.
I. Background
According to Respondent INTERNAL REVENUE SERVICE's ("IRS") records, Petitioner MARILYN PETERS, a citizen of California, did not file tax returns for the tax years 1978 through 1981. Duncan Decl. at ¶ 4. In June 1987, the IRS sent Petitioner Statutory Notices of Deficiencies for these tax years. Id. The deficiencies were assessed after the expiration of the 90 day period for filing a Tax Court petition pursuant...
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