David A. Lehmann - Page 15

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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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