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without merit. The notice was mailed to and actually received by
petitioner at his last known address. Sec. 6212(b); see Erhard
v. Commissioner, 87 F.3d 273 (9th Cir. 1996), affg. T.C. Memo.
1994-344; Frieling v. Commissioner, 81 T.C. 42, 53 (1983). We
find that the notice is valid and turn to the question of whether
respondent correctly determined petitioner's tax liability.
Respondent's determination that petitioner is liable for a
$16,842 deficiency is presumed correct, and petitioner bears the
burden of proving it erroneous. Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933). Petitioner conceded that he received
wages, but contended that his "hard work [did not] [constitute]
* * * taxable income." Petitioner's contention is groundless.
Accordingly, we reject it and hold that petitioner is liable for
the deficiency.
Respondent also determined that petitioner, pursuant to
section 6654, is liable for an addition to tax for failing to
make estimated tax payments. Petitioner has the burden of
proving that respondent's determination is erroneous. Rule
142(a); Baldwin v. Commissioner, 84 T.C. 859, 871 (1985).
Petitioner did not offer any evidence relating to this issue.
Therefore, we hold that petitioner is liable for the section 6654
addition to tax.
Respondent also determined that petitioner, pursuant to
section 6651, is liable for an addition to tax for failing to
file a tax return in a timely manner. In response, petitioner
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