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As indicated, respondent filed a Motion to Dismiss For Lack
of Jurisdiction in which she asserts that petitioners failed to
file their petition within the 90-day period prescribed by
section 6213(a). Petitioners filed an objection to respondent's
motion in which they assert that the notice of deficiency was not
mailed to them at their last known address. In this objection,
petitioners identify their last known address as 2420 San Bruno
Ave., San Francisco, California. Respondent filed a response to
petitioners' objection in which she asserts that the notice of
deficiency was mailed to petitioners at their last known address.
Hearings were conducted in this case in Washington, D.C.
Counsel for respondent appeared at the hearings and presented
argument in support of the pending motion. Although petitioners
did not appear at the hearings, they did file a written statement
with the Court pursuant to Rule 50(c).
Discussion
This Court's jurisdiction to redetermine a deficiency
depends upon the issuance of a valid notice of deficiency and a
timely filed petition. Rule 13(a), (c); Monge v. Commissioner,
93 T.C. 22, 27 (1989); Normac, Inc. v. Commissioner, 90 T.C. 142,
147 (1988). Section 6212(a) expressly authorizes the
Commissioner after determining a deficiency to send a notice of
deficiency to the taxpayer by certified or registered mail. It
is sufficient for jurisdictional purposes if respondent mails the
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