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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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