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Plainview, Detroit, MI 48228-1070792, on December 1, 1998. On or
about November 23, 1998, the IRS had received from petitioner a
copy of a Form 1040 for 1992, and both the return and the
envelope in which it arrived reflected the Plainview address.
Petitioner also stated at the hearing on respondent’s motion that
he moved from the Plainview address in 1999 or 2000. Thus, the
evidence shows that the notice of deficiency was sent in a manner
in compliance with, and valid under, section 6212 and
corresponding regulations, requiring that a notice of deficiency
be sent to a taxpayer’s last known address. See sec. 6212(a) and
(b)(1).
However, section 6330(c)(2)(B) focuses upon receipt of the
notice of deficiency. During the administrative proceedings,
petitioner apparently indicated that he “did not receive” or “did
not recall receiving the Statutory Notice of Deficiency”. He was
therefore provided with an opportunity to present information for
reconsideration of the liability but submitted no substantiating
materials by a deadline established for that purpose. At the
hearing on respondent’s motion, following a lengthy explanation
from the Court regarding certified mail procedures, petitioner
never expressly denied receiving either (1) notification of a
certified letter to be claimed or (2) the notice of deficiency
itself. He merely stated that the IRS had been unable to “give *
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