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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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