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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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Last modified: May 25, 2011