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actual receipt of the deficiency notice by Ms. Steinhauer on
December 18, 1995. In addition, petitioners contend that they
received and relied on advice from the IRS regarding the due date
of the petition.
Discussion
This Court's jurisdiction to redetermine a deficiency
depends upon the timely 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)
authorizes the Secretary or his delegate, upon determining that
there is a deficiency in income tax, to send a notice of
deficiency "to the taxpayer by certified or registered mail."
Section 6212(b) provides that a notice of deficiency, in respect
of an income tax, "shall be sufficient", if it is "mailed to the
taxpayer at his last known address". Generally, the Commissioner
has no duty to effectuate delivery of the notice after it is
mailed. Monge v. Commissioner, supra at 33.
Neither section 6212 nor the regulation promulgated
thereunder, section 301.6212-1, Proced. & Admin. Regs., defines
what constitutes a taxpayer's "last known address". We have
defined it as the taxpayer's last permanent address or legal
residence known by the Commissioner, or the last known temporary
address of a definite duration to which the taxpayer has directed
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