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petitioner’s demeanor at trial, his lackadaisical attitude in his
dealings with respondent and this Court, and his propensity for
blaming others for his troubles, we do not regard petitioner as a
credible witness, particularly in regard to this matter. In any
event, there is no evidence to suggest that the notice of
deficiency could not be delivered to the Madeira address to which
it was addressed or that it was ever returned to respondent.
On the basis of all the evidence, we conclude that
petitioner actually received the notice of deficiency dated
May 17, 1995, sometime before June 15, 1995–-well in time to
petition the Tax Court. Accordingly, pursuant to section
6330(c)(2)(B), petitioner is precluded from challenging his
underlying tax liability in this proceeding.9
IV. Validity of the Notices of Determination
The notices of determination correctly state in their
headings that the instant collection proceeding relates to
petitioner’s tax period that ended December 1992. Identical
attachments to each notice of determination also state in their
initial paragraphs: “The balance due at issue is for Mr. Casey’s
1992 individual tax (from 1040) for 1992.” In discussing
9 Notwithstanding the preclusion rule of sec. 6330(c)(2)(B),
Appeals Officer Cody offered to consider petitioner’s mileage
records informally. Cody’s offer of informal consideration,
which evinces good faith on her part, does not entitle petitioner
to dispute his underlying tax liability in this proceeding. See
Behling v. Commissioner, 118 T.C. 572, 578-579 (2002); sec.
301.6330-1(e)(3), Q&A-E11, Proced. & Admin. Regs.
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