Harold E. Call - Page 14

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          warrant further consideration of the merits of his case by the              
          Appeals Office or this Court.  Petitioner, however, continued to            
          focus on the denial of a recorded hearing and offered no                    
          substantive issues of merit.                                                
               Hence, despite repeated warnings and opportunities, the only           
          contentions other than the recorded hearing advanced by                     
          petitioner are, as will be further discussed below, of a nature             
          previously rejected by this and other courts.  The record                   
          therefore does not indicate that any purpose would be served by             
          remand or additional proceedings.  The Court concludes that all             
          pertinent issues relating to the propriety of the collection                
          determination can be decided through review of the materials                
          before it.                                                                  
                    2.  Review of Underlying Liabilities                              
               Statutory notices of deficiency for 1998 and 1999 were                 
          issued to petitioner by certified mail.  Furthermore, statements            
          in the memorandum of law filed in support of petitioner’s                   
          response to respondent’s earlier motion for summary judgment make           
          clear that he received the notices, despite assertions in various           
          other documents that might suggest the contrary.  In addition,              
          the following colloquy on this subject took place at trial:                 
                    THE COURT:  All right.  I have one question, Mr.                  
               Call.  The order that I previously entered in your case                
               denying the motion for summary judgment noted that the                 
               service had issued statutory notices of deficiencies to                
               you for both the years of ’98 and ’99.                                 






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