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not reflect the date that petitioner personally received the
notice of deficiency.
Petitioner filed a petition for redetermination with the
Court on February 20, 1996. The petition arrived at the Court in
an envelope bearing a U.S. postmark dated February 14, 1996. At
the time the petition was filed, petitioner resided in Spokane,
Washington.
As indicated, respondent filed a Motion to Dismiss For Lack
of Jurisdiction alleging that petitioner failed to file her
petition within the 90-day period prescribed in section 6213(a).
Petitioner filed an objection to respondent's motion to dismiss
alleging that the deficiency notice was not mailed to her correct
last known address, which she identifies as the 2411 Ingleside
Avenue address. Respondent filed a response to petitioner's
objection countering that the deficiency notice was mailed to
petitioner's last known address. Petitioner filed a Motion to
Dismiss for Lack of Jurisdiction on the ground that the notice of
deficiency is invalid.
A hearing was conducted in this case in Washington, D.C.
Counsel for respondent appeared at the hearing and presented
argument in support of respondent's motion to dismiss. Although
petitioner did not appear at the hearing, her position is clearly
articulated in her motion to dismiss, her objection to
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