Anthony Sciola - Page 7

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          deficiency were mailed to him.  Nor did petitioner testify that             
          he did not receive the notices.3                                            
               The parties have stipulated, and the record establishes,               
          that respondent mailed the notices of deficiency to petitioner at           
          his residence.  In the absence of sufficient evidence to the                
          contrary, and in the absence of an affirmative denial by                    
          petitioner that he received the notices, we conclude that                   
          petitioner, in fact, received the notices.  See Sego v.                     
          Commissioner, supra at 611 (“In the absence of clear evidence to            
          the contrary, the presumptions of official regularity and of                
          delivery justify the conclusion that the statutory notice was               
          sent and that attempts to deliver were made in the manner                   
          contended by respondent.”).                                                 
               In his petition and at trial, petitioner disputes only the             
          underlying 1995 and 1996 tax liabilities.  However, because                 
          petitioner received the notices of deficiency, he is precluded              
          from contesting the underlying tax liabilities in this case.                
          Sec. 6330(c)(2)(B); Goza v. Commissioner, 114 T.C. 176 (2000).              
          Petitioner has not set forth any other arguments concerning                 
          respondent’s determination, such as a spousal defense, a                    
          challenge to the appropriateness of collection activities, or an            
          offer of a collection alternative.  Nor has petitioner alleged              

          3Petitioner likewise offered no evidence concerning the                     
          underlying tax liabilities, stating that he had been informed               
          that the underlying deficiencies would not be addressed at trial.           





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