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MR. ROBERTS: * * * What I’ve argued is, you
know, these added monies that they’ve put in for like
having a business, which I never had any business.
THE COURT: I know, but your time to do that was
when you got the certified letter, and you should have
filed a petition in the Tax Court to challenge it, but
you didn’t do that. That’s the problem here, which I
keep--I’m trying to explain to you.
MR. ROBERTS: Okay. I understand. But I’m not
sure if I ever got this--what they’re saying, and
that’s why I asked them if they had some, you know--me
sign something or whatever, that type--’cause I
honestly don’t think I ever got one.
Finally, petitioner was asked directly to explain his
allegations of nonreceipt:
THE COURT: Why do you say you never got the
notice of deficiency?
MR. ROBERTS: I don’t honestly remember ever
getting it. And there was a--
THE COURT: You just don’t remember getting it, or
are you saying positively you didn’t get it? Which is
it?
MR. ROBERTS: I’m pretty sure or positively, I
guess, that I didn’t get it ’cause there was a fire at
that--it’s like a fourplex. So for--you know, I never
lived there all the time and stuff, you know, ’cause I
lived with other friends and stuff and that was kind of
like a mailing address, kind of.
THE COURT: But that was your address, though--I
mean, mailing address?
MR. ROBERTS: Yeah, one of ’em. But then I moved-
-you know, I lived in a lot of different places down on
the beach area.
THE COURT: Well, you used that address when you
filed those delinquent returns. Is there any
particular reason why you did that?
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Last modified: May 25, 2011