Peters

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 If 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 to statutory authority. Id. The IRS also found audit deficiencies in Petitioner’s tax returns for the tax years 1982, 1983, 1986, 1987, and 1992, and sent Petitioner Statutory Notices of Deficiencies for these years as well. Id. at ¶ 5. No United States Tax Court petition was filed on behalf of Petitioner. The deficiencies were assessed after the expiration of the 90 day period for filing a Tax Court petition pursuant to statutory authority. Id. On July 5, 1995, the IRS filed a “Notice of Levy on Wages, Salary, and Other Income” against Petitioner for the years 1978 through 1992, for a total of $90,-866.63. Complaint at ¶ 7. On August 18, 1995, Petitioner filed a document entitled “Libel of Review, Answer of Marilyn Peters Complaint of Involuntary Servitude…