Nemat Mostaan - Page 7

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          has no knowledge of the alleged letters of notification and did             
          not receive them.  As in the case of the claimed telephone                  
          notification calls, petitioner failed to present any                        
          substantiation of the evidence beyond his own testimony.  Under             
          the circumstances of this case, and in view of petitioner's                 
          repeated presentation of unsubstantiated evidence, we are not               
          convinced of the authenticity of the supposed letters of                    
          notification.  We are not required to accept petitioner's self-             
          serving testimony.  Tokarski v. Commissioner, 87 T.C. 74, 77                
          (1986).                                                                     
          Accordingly, we hold that in this case the notice of                        
          deficiency for the years in issue was mailed to petitioner's last           
          known address by certified mail and that petitioner failed to               
          provide respondent clear and concise notification of an address             
          change prior to the date of mailing of the deficiency notice.               
          2.  Actual Receipt                                                          
          Even if the deficiency notice here had been improperly                      
          addressed, nevertheless the notice would be valid since the                 
          record shows that petitioner received actual notice of                      
          respondent's deficiency determination in time for him to file a             
          petition within the 90-day period after mailing of the notice.              
          See Mulvania v. Commissioner, supra at 68-69.                               
          The postman who delivered mail at 2407 Lascar Place                         
          testified that he had spoken with petitioner on numerous                    
          occasions, that he regularly delivered mail addressed to                    




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