E. Neal Figler - Page 9

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               Petitioner struggles to convince us by raising meritless               
          arguments that respondent did not properly mail, and petitioner             
          did not receive, the notice of deficiency.  Petitioner argues,              
          among other things, that there could have been a mistake because            
          Pam Butler, respondent’s clerk who mailed the notice of                     
          deficiency, did not place a check mark next to each name on Form            
          3877, despite testimony from John Bohan and Pam Butler that the             
          notice of deficiency and the mailing labels were double checked             
          before the Form 3877 was generated and from Dwight Davies that              
          the post office checks the article numbers on the pieces of                 
          certified mail against the article numbers listed on Form 3877.             
          Petitioner also argues that respondent’s settlement officers                
          deliberately withheld, refused to look for, or destroyed                    
          exculpatory evidence because they were afraid of losing their               
          jobs and perjured themselves to “cover up that fact.”                       
          Specifically, petitioner asserts that respondent’s settlement               
          officers did not obtain evidence of a certified mail signed                 
          receipt.  We find petitioner’s arguments lacking in merit.                  
               Other than his self-serving testimony that he never received           
          the notice of deficiency, petitioner has not produced sufficient            
          credible evidence to overcome the strong presumption of proper              
          mailing and delivery in the instant case.  See Sego v.                      
          Commissioner, supra at 611; see also Zenco Engg. Corp. v.                   
          Commissioner, supra at 323 (stating “tax cases could all become             

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