Francisco and Angela Aguirre - Page 6




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          fact that section 6330 now provides an opportunity to contest tax           
          liability for taxpayers who did not receive a notice of                     
          deficiency, sec. 6330(c)(2)(B), provides no consolation to                  
          petitioners who themselves made the choice not to receive such              
          notice, see Sego v. Commissioner, 114 T.C. 604, 611 (2000)                  
          (taxpayers who deliberately refused to accept delivery of the               
          notices of deficiency repudiated the opportunity to contest the             
          notices of deficiency in the Tax Court).                                    
               Second, by failing to file a response to respondent’s motion           
          and to attend the calendar call, or have someone appear on their            
          behalf, petitioners waived their right to contest the motion.               
          Rule 121(d); Lunsford v. Commissioner, 117 T.C.      (2001).                
               Accordingly, we will grant respondent's motion for summary             
          judgment.                                                                   


                                             An appropriate order and                 
                                        decision will be entered.                     


















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