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to dispute the liability, the Court has held that taxpayers
cannot defeat actual receipt by deliberately refusing delivery of
a statutory notice. Sego v. Commissioner, 114 T.C at 610-611;
Tatum v. Commissioner, T.C. Memo. 2003-115; Carey v.
Commissioner, T.C. Memo. 2002-209; Baxter v. Commissioner, T.C.
Memo. 2001-300. Here, the testimony given at trial suggests that
petitioner’s communication of the West Deer Valley address to the
Internal Revenue Service in January of 1999, and subsequent
failure to notify of any new addresses, may have been a
deliberate preemptive attempt to prevent delivery of any notice
of deficiency. The substantial nature of the relevant tax
deficiencies, exceeding $250,000 for each of the years in issue,
further enhances the likelihood of this scenario. To the extent
that the West Deer Valley address had been outdated for 8 years
or “since 1996” at the time of trial in October of 2004, the 1999
letter would have been inaccurate when written. Petitioner would
reasonably be considered in such circumstances to have
deliberately repudiated his opportunity to contest the notices of
deficiency in this Court and likewise now to be precluded from
challenging his underlying liability in this proceeding.
Nonetheless, even if petitioner were entitled to contest his
underlying liabilities at this juncture, he has at no time
offered even a scintilla of evidence that would show error in
respondent’s determinations. He declined at trial to address in
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