MEMORANDUM OPINION
MARVEL, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of prosecution.
Background
Petitioner did not file Federal income tax returns for 1997, 1998, 2000, and 2001. By a notice of deficiency dated October 28, 2003, respondent determined deficiencies in income tax and additions to tax under sections 6651(a)(1)
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