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be hard pressed to hold that respondent is not entitled to rely
upon tax-return information in his possession (including
petitioner’s own description of CM Trust) in determining how,
where, and to whom to mail the FPAA. See Waring v. Commissioner,
412 F.2d 800, 801 (3d Cir. 1969) (holding that statements in a
tax return are admissions that are not overcome without cogent
evidence that they are wrong), affg. per curiam T.C. Memo.
1968-126; Estate of Hall v. Commissioner, 92 T.C. 312, 337-338
(1989) (same).
Petitioner has stipulated that he will concede the
correctness of respondent’s determination of the income tax
deficiency if the Court concludes, as we do, that respondent’s
mailing of the FPAA to petitioner met the notice requirement of
section 6223(a). We apply that stipulation and will enter a
decision accordingly.8 We have considered all arguments made by
8 Petitioner attempts to disregard this stipulation by
arguing in brief that the Court should hold for him on equitable
grounds because of his young age. We decline to consider this
argument, limiting the grounds for our decision to the single
issue that the parties have placed before the Court through their
stipulation.
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