Roy Watson - Page 10




                                       - 10 -                                         
               Petitioner claims that he did not receive the notice of                
          deficiency.  By letter dated November 18, 1994, however,                    
          petitioner acknowledges receiving correspondence from respondent            
          dated September 28, 1994, the date of the notice of deficiency.             
          With respect to that correspondence, petitioner states:                     
          “[H]owever, I am not a person required to file.”  Respondent also           
          has a return receipt from the U.S. Postal Service showing receipt           
          by petitioner of the notice of deficiency.  That receipt shows a            
          signature in petitioner’s name.  Petitioner denies that he signed           
          the receipt.  Petitioner offers no explanation for the signature.           
          We do not believe petitioner when he claims that he did not sign            
          the receipt and did not receive the notice of deficiency.  We               
          have found that petitioner did receive the notice of deficiency.            
               E.  Conclusion                                                         
               We have reviewed the notice in light of petitioner’s claims            
          and we find no error.  We deny petitioner any relief.                       
          IV.  Section 6673(a)(1)                                                     
               In pertinent part, section 6673(a)(1) provides a penalty of            
          up to $25,000 if proceedings before the Tax Court have been                 
          instituted or maintained by the taxpayer primarily for delay or             
          the taxpayer’s position in the proceeding is frivolous or                   
          groundless.  In the petition and in communications to respondent            
          and this Court, petitioner insists that he has no tax liability             
          notwithstanding that he has paid nothing to respondent.  He                 






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