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However, petitioner failed to present any documentary
evidence, such as a copy of the return or mailing receipt, which
would substantiate his claim that he mailed either the Federal
return or an application for extension to file the Federal
return. If petitioner is contending that the 1983 Federal return
was mailed at the same time as the California return, it would
not have been mailed until 1991. Moreover, given the conceded
items of income and the claimed deductions and exemptions based
on the California return, it is likely that a tax would have been
due and owing, inasmuch as petitioner had eliminated any
withholding of taxes from his wages. However, petitioner
received no bills from respondent and made no payments to
respondent. Accordingly, we find that petitioner did not file a
Federal return for 1983. Thus, it follows that the period of
limitations does not bar assessment of the deficiency and
additions to tax for that year. Sec. 6501(c)(3).
Burden of Proof
Petitioner argues that the notice of deficiency should not
be accorded the normal presumption of correctness. See Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933). Specifically,
petitioner argues that the notice of deficiency is arbitrary and
unreasonable because he mailed the Federal return, he was married
during 1983, and the notice of deficiency attributed all of the
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