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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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