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in that return. Respondent further determined in the notice that
petitioner is liable for the accuracy-related penalty under
section 6662(a).
Discussion
The only argument that petitioner advanced at trial is that
the notice that respondent issued to him with respect to his
taxable year 2000 is invalid because the office of respondent
which issued that notice is located in Holtsville, New York, and
not in Memphis, Tennessee, where petitioner resided at all
relevant times.2 We reject that argument. There is no require-
ment in the Internal Revenue Code that the office of respondent
which issues a notice to an individual taxpayer must be located
where such taxpayer lives.
To reflect the foregoing,
Decision will be entered
for respondent.
2Petitioner expressly declined to advance any contentions or
arguments at trial with respect to the determinations that
respondent made in the notice relating to his taxable year 2000.
We conclude that petitioner has abandoned contesting such deter-
minations.
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Last modified: May 25, 2011