Donald B. Hawksley - Page 26




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          30-day letter for 1986 that was mailed to him in October 1989;              
          regardless, petitioner received the notice of deficiency for 1986           
          that was mailed to him in March 1990.  Yet petitioner did                   
          nothing.  He did not protest the 30-day letter; he did not file a           
          petition with this Court; he did not even contact Mr. Amigron to            
          inquire what his supposed representative was doing on his behalf            
          or what his supposed representative recommended be done.                    
               It should be recalled that Mr. Amigron was not arrested                
          until May 1991.  Thus, if petitioner had protested the 30-day               
          letter in September or October 1989 or had filed a petition with            
          this Court in March 1990, petitioner would have had the                     
          opportunity of substantiating his return with what he alleges               
          were impeccably maintained records.                                         
               Further, although petitioner testified that respondent                 
          returned his records to him at or about the end of 1993,                    
          petitioner did not file an amended return for 1986 until January            
          1996, some 2 years later.  Even then, after respondent’s Problem            
          Resolution Office demonstrated a willingness to abate                       
          petitioner’s 1986 income tax, petitioner failed to produce                  
          documentation for his Schedule C deductions.  Indeed, it was not            
          until April 1998, yet another 2 years later, that petitioner                
          finally produced such documentation, which respondent promptly              
          accepted.                                                                   
               In view of the foregoing, we conclude that petitioner’s                






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