- 24 -
was sent to an address where petitioner no longer lived.13 We
infer that petitioner would have appealed the proposed deficiency
if petitioner had known about it. Taking into account the fact
that petitioner did not receive the 30-day letter, we reject
respondent's contention that petitioner failed to exhaust
administrative remedies. See sec. 301.7430-1(e)(2), Proced. &
Admin. Regs.
III. Protraction of Proceedings
Respondent contends that petitioner unreasonably protracted
the court proceeding because petitioner failed to provide
"relevant information immediately after the issuance of the
Notice of Deficiency". In respondent's view, if petitioner had
provided such information, then respondent could have rescinded
the notice of deficiency.
As previously discussed, respondent did not offer to rescind
the notice of deficiency in spite of (1) the infirmities evident
on the face of the Forms 1099-G, and (2) the information
furnished by petitioner and petitioner's counsel after the notice
was issued. Thus, we reject respondent's contention that
petitioner unreasonably protracted the court proceeding.
IV. Reasonableness of the Amount of Costs Claimed
13 See supra note 12.
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