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amended returns filed by petitioner for 1990-1993, concluding
that the amended returns were frivolous and that petitioner had
shown no basis for modifying the tax shown as due on the
originally submitted returns. At trial, petitioner was evasive
regarding the source of his income and claimed that his income
was not in any event taxable because he had merely received money
in exchange for labor.
Petitioner has advanced only unspecified or frivolous
challenges to his underlying tax liabilities (including the
additions to tax) for 1990 through 1993. We accordingly conclude
that the underlying liabilities are correct.
With respect to the underlying liability for 1996, at trial
and in his request for a hearing, petition, and absentee letter,
petitioner maintained that he did not receive a notice of
deficiency for 1996 and sought to contest the underlying
liability for that year. Respondent maintains that petitioner is
precluded from challenging the underlying liability for 1996
under section 6330(c)(2)(B) because he received a notice of
deficiency for that year.
To counter petitioner's denial that he received the notice
of deficiency for 1996, respondent points to the fact that the
notice was addressed to petitioner at his current address, an
address where petitioner indisputably received other IRS
correspondence, because that correspondence was responded to by
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