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more than 90 days after the mailing of the second deficiency
notice. Respondent argues that the petition was untimely and
should be dismissed for lack of jurisdiction.
Petitioners contend that the notices of deficiency were not
mailed to their last known address. Petitioners argue that,
because petitioner submitted to Revenue Officer Mills a power of
attorney on March 19, 1993, listing the Brownway address as
petitioners' current address, and because Revenue Officer Mills
possessed independent knowledge that the Brownway address was
petitioners' address at that time, the Internal Revenue Service
had clear and concise notice of petitioners' change of address to
the Brownway address, prior to the issuance of the two notices of
deficiency. We need not address petitioners' contentions in
those respects. As explained more fully below, we hold that the
notices in question are valid on the ground that petitioners
received "actual notice" of respondent's deficiency determina-
tions, since the notices in question were promptly forwarded to
petitioners' Brownway address.
The purpose of section 6212 is "to afford a taxpayer notice
of the Commissioner's determination and an opportunity to liti-
gate the validity of such determination in this Court without
first paying the claimed deficiency." Mulvania v. Commissioner,
81 T.C. 65, 67 (1983), affd. 769 F.2d 1376 (9th Cir. 1985).
The purpose of section 6212 is accomplished when the
taxpayer receives "actual notice" of the deficiency determination
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