Gene C. Smith - Page 4




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          last known address and that he did not receive the notices of               
          deficiency.  Respondent asserts that petitioner’s underlying tax            
          liability is not before the Court.  Respondent contends that                
          there is no evidence petitioner did not receive the notices of              
          deficiency.                                                                 
               The parties ask the Court to decide primarily whether                  
          petitioner received a notice of deficiency for any of the subject           
          years.  If he did, he would be precluded from challenging his               
          underlying tax liability for the related year or years.  We need            
          not and do not decide that issue.  Assuming arguendo that                   
          petitioner did not receive a notice of deficiency for any of the            
          subject years and thus was entitled to challenge his underlying             
          tax liability for each of those years, he has not established               
          that he is entitled to any of the additional deductions which he            
          claims.  Petitioner did not provide at trial any evidence, in the           
          form of either testimony or documentation, to support his claim             
          to any additional deduction.  In fact, he chose to present no               
          evidence at all other than by way of the stipulated facts and               
          exhibits, none of which adequately supports his claim.  Given               
          that petitioner set forth in his petition no allegation that                
          respondent abused his discretion, that petitioner has not claimed           
          that the proposed method of collection is inappropriate, that               
          petitioner has not offered any alternative means of collection,             








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