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previously rejected petitioner’s contentions in Allnutt II (at
paragraph C of the opinion).
In Allnutt II, petitioner alleged that respondent did not
timely provide to him Forms 895 for tax years 1987-98.8 In
Allnutt II, we said that petitioner had not shown that respondent
withheld the Forms 895 in bad faith, that respondent violated any
order, or that respondent’s counsel’s conduct was fraudulent. In
the current motion, petitioner has offered no new evidence and he
has made no new arguments relevant to this issue. We conclude
that we properly denied petitioner’s motions for a hearing.
To reflect the foregoing,
Decision will be
entered under Rule 155.
8 Petitioner erroneously believes that the Forms 895 show
that he filed his returns for the years in issue in February
1997, and, thus, that the notice of deficiency was untimely.
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