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jurisdiction.” The District Court dismissed petitioners’ lawsuit
on or after that date.
Petitioners petitioned this Court on November 16, 1999, to
redetermine respondent’s determination. Petitioners resided in
Orange, California, at that time.
Discussion
Our jurisdiction requires a valid notice of deficiency and a
timely filed petition, and when one or both of these items is
missing, we must dismiss a case for lack of jurisdiction. See
sec. 6213(a); Cross v. Commissioner, 98 T.C. 613, 615 (1992); Pyo
v. Commissioner, 83 T.C. 626, 632 (1984). Section 6213(a)
provides that where a notice of deficiency is addressed to an
individual within the United States, he or she may petition this
Court within 90 days of the mailing of the notice of deficiency
to redetermine the deficiency.
Petitioners argue primarily that the notices of deficiency
mailed to their last known address were invalid because, they
assert, the notices failed to include all information required by
section 6212(a). We disagree with this assertion. We find as a
fact that the notices of deficiency mailed to petitioners’ last
known address contain all statutorily required information.
Petitioners point to the fact that respondent’s files contain one
copy of the notices of deficiency mailed to the Collins address,
one copy of the notices mailed to the Willow address, and one
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