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collection of the tax may be begun without assessment, at any time.
Sec. 6501(c)(3).
The only evidence to support petitioner's assertion that he
timely filed a 1989 return is his own testimony. And in this
respect, petitioner's testimony was sketchy. Petitioner offered no
proof concerning the date of mailing, nor did he testify as to the
circumstances attending the purported mailing. Petitioner did not
maintain a signed copy of the 1989 return allegedly filed. To
refute petitioner's assertion, respondent introduced an IRS
certificate of lack of record, dated January 8, 1998, to indicate
that petitioner did not file a return for 1989.
The record reflects that petitioner wrote letters to the IRS
District Director of the Fresno Service Center and the IRS Director
of Foreign Operations in Washington, D.C., on December 2, 1991,
indicating that he is not a "taxpayer" and is not required to file
tax returns. Additionally, on February 5, 1992, petitioner wrote
letters to these offices, stating: "Your office sent out a letter
requesting a tax return, I returned a letter to your office denying
that I was required to file a return, because I could not locate
any specific part of the revenue code that made me liable for
filing any sort of a return."
On the basis of the implications which can be drawn from
petitioner's letters to the IRS, as well as the entire record
before us, we are unable to conclude that petitioner filed a return
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