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community income to him. In addition, petitioner contends that
the proof of claim filed by the IRS in the bankruptcy proceeding
indicates the 1983 Federal income tax owed was $900, that the IRS
has a history and reputation for making mistakes in processing
returns, and that respondent did not offer the necessary
foundational information into evidence to support the notice of
deficiency.
It is well established that, in the absence of exceptional
circumstances, the Court will not look behind a deficiency notice
to determine whether the Commissioner's agents followed proper
administrative procedures. Human Engg. Inst. v. Commissioner, 61
T.C. 61, 66 (1973); see also Greenberg's Express, Inc. v.
Commissioner, 62 T.C. 324, 327 (1974). Even in such exceptional
circumstances, the Court will generally not hold the deficiency
notice null and void to relieve the taxpayer of any tax
liability. Greenberg's Express, Inc. v. Commissioner, supra at
328.
With respect to petitioner's argument that the notice of
deficiency is arbitrary and unreasonable because it is erroneous,
we disagree. Petitioner's testimony, standing alone, that he
signed the Federal return and gave it to Mr. Henschel to mail
does not establish that the Federal return was actually mailed.
Moreover, the fact that respondent allocated all of the community
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