CUMMINGS, Circuit Judge.
On June 28, 1986, the Internal Revenue Service (IRS) sent a notice of income tax deficiency by certified mail to the home address of plaintiff Victor H. Goulding. Because Goulding was purportedly on vacation when the notice was sent, he did not receive the notice which was returned to the IRS. In January, 1987, the IRS assessed the deficiency with interest and penalties in the amount of $45,919.72. Goulding paid this amount in June, 1987....
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