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This Court has determined that the 150-day period applies
not only to persons who are outside of the United States "on some
settled business and residential basis," but also to persons who
are temporarily absent from the country. Levy v. Commissioner,
76 T.C. 228, 231 (1981). In addition, the taxpayer's absence
from the country must result in delayed receipt of the deficiency
notice. Lewy v. Commissioner, 68 T.C. 779, 783 (1977).
In Levy v. Commissioner, supra, the taxpayers left their
home in Chicago for a vacation in Jamaica on the same day that
the notice of deficiency was mailed to them. The taxpayers
returned to their home 5 days later, at which time they received
the notice of deficiency. In holding that the 150-day period
applied, this Court found that, "the full 90-day period for
reviewing their position and determining their options was not
available to the * * * [taxpayers], and it was this precise
hardship which occasioned the drafters to allow 150 days for a
response where the taxpayer is abroad." Id. at 231.
The evidence in this case establishes that petitioner
departed on Korean Airlines flight number 11, from Los Angeles,
California, to Seoul, South Korea, on March 19, 1997, the day the
notice of deficiency was issued. Prior to his departure from the
United States, petitioner put his mail delivery on hold at his
local post office. Petitioner arrived in the Philippines, his
destination on this journey, on March 21, 1997. On April 3,
1997, petitioner left the Philippines and returned directly to
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