MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
The issues before us are whether petitioner has received a notice of deficiency for 1999 or otherwise had an opportunity to dispute his tax liability for 1999, and whether petitioner is required to file a Federal income tax return to be allowed his claimed bases in securities he sold in 1999.
The petition in this case was filed under section 6330(d)
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