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notices of deficiency was presented in his opening statement. He
argues:
While the IRS apparently had mailed a notice of
deficiency or a tax lien to me, I was away from the
residence on a protracted job assignment that was typical
for the work that I had to do, like six months. Didn’t --
did not default because not having the notification, I
wasn’t aware that I had a time limitation. And so the
default happened because of that situation, not that I, you
know, knowingly ignored it.
We do not interpret this argument to be an affirmative denial
that petitioner received the notices of deficiency. First,
petitioner does not argue that respondent mailed the notices of
deficiency to an incorrect address or that the notices otherwise
did not arrive at his residence in a timely manner. Second, we
do not accept petitioner’s implication that a period of
employment away from his home would entail an inability to
receive mail. Finally, petitioner did not offer testimony or
other evidence concerning any details of his receipt, or failure
to receive, the notices of deficiency. Petitioner merely
testified that he was sometimes away from his residence for 6-
month periods of time, and he described the general nature of his
employment as the installation of digital cellular phone systems.
However, petitioner did not attempt to correlate any absences
from his residence with the time period when the notices of
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