David Richardson - Page 4

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          certified mail.2  Accordingly, we conclude that the notice is               
          valid and shall deny petitioner's motion to dismiss for lack of             
          jurisdiction.                                                               
                                             An appropriate order will be             
                                        issued.                                       

























               2 Petitioner filed a motion for the production of documents            
          on Apr. 2, 1998, in which he again argues that this case should             
          be dismissed because respondent has offered no evidence showing             
          that petitioner signed for the notice of deficiency when it was             
          delivered.  Petitioner also requests that respondent produce the            
          documents used to calculate petitioner's deficiency.  In this               
          opinion we address only the issue of jurisdiction.  Because we              
          conclude that we have jurisdiction, issues concerning the                   
          correctness of respondent’s determination would be considered in            
          a later proceeding.                                                         



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