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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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