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declined to grant respondent’s motion for summary judgment. The
record as it then existed did not foreclose the possibility that
petitioner might have raised valid arguments had a hearing been
held. Accordingly, we provided petitioner an opportunity before
the Court at the trial session in Phoenix to identify any
legitimate issues he wished to raise that could warrant further
consideration of the merits of his case by the Appeals Office or
this Court.
At trial, the comments of petitioner and his wife focused
almost exclusively on petitioner’s assertion that he did not
receive the notices of deficiency and on corollary matters
regarding his address. However, as will be explained in greater
detail below, petitioner failed to raise any legitimate
substantive issues requiring or justifying additional review
under the framework of section 6330. 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
The evidentiary record establishes that statutory notices
determining deficiencies with respect to the 1993, 1994, 1995,
1996, and 1997 taxable years were issued to petitioner.
Respondent’s records indicate that the notices were returned as
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