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duties, which justifies the conclusion that the notice of
deficiency was sent and that attempts to deliver the notice
were made in the manner contended by respondent. Sego v.
Commissioner, 114 T.C. 604, 611 (2000).
The record in this case contains a copy of a notice of
deficiency dated June 18, 2003, addressed to petitioner; a
Form 3877 indicating that the notice was sent on the date it
bears; and notations made by the United States Postal
Service showing that it attempted delivery on 3 separate
occasions over a 4-week span of time. Accordingly, we
conclude that although petitioner did not accept delivery of
the notice of deficiency, his failure to receive the notice
actually stemmed from a deliberate effort to refuse such
delivery in furtherance of his ill-conceived line of
reasoning that he is exempt from any income tax liability.
It is well settled that a notice of deficiency mailed to the
taxpayer’s last known address in accordance with the
provisions of section 6212(b) is valid irrespective of
whether or not the taxpayer actually received it. See Pyo
v. Commissioner, 83 T.C. 626, 632 (1984); Frieling v.
Commissioner, 81 T.C. 42, 48 (1983); Zenco Engg. Corp. v.
Commissioner, 75 T.C. 318, 321 (1980), affd. without
published opinion 673 F.2d 1332 (7th Cir. 1981).
We find that petitioner’s conduct in this case
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