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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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Last modified: May 25, 2011