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his testimony that he “[didn’t] * * * recall receiving it” and he
“did not document the receipt of it.” Petitioner admits that
respondent mailed the notice of deficiency to the proper address,
and petitioner received several other items of correspondence
mailed by respondent to the same address both before and after
the notice of deficiency was issued. Because petitioner has not
produced any convincing evidence to rebut the presumption of
delivery, we find that petitioner received the notice of
deficiency.
B. Other Opportunity To Dispute 1995 and 1996 Tax
Liabilities
Petitioner also argues that he did not have an opportunity
to dispute his 1995 and 1996 tax liabilities because he was
suffering from severe health problems that began in late 1998 and
continued through 2000.
Section 6330(c)(2)(B) provides that a taxpayer may dispute
the existence or amount of unpaid tax liability if he did not
receive a notice of deficiency or otherwise have an opportunity
to dispute such tax liability. The “opportunity to dispute such
tax liability” includes a conference with the Appeals Office,
either before or after the tax liability is assessed. Sec.
301.6330-1(e)(3), Q&A-E2, Proced. & Admin. Regs.
Even if we assume that petitioner did not receive the notice
of deficiency mailed by respondent on April 15, 1999, the record
establishes that petitioner had several opportunities between
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