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mailed to petitioner's last known address. Thereafter,
petitioner filed a supplemental objection stating that she was
unaware of the deficiency notice until early in 1995.
A hearing was conducted in this case on November 8, 1995, in
Washington, D.C. Counsel for respondent appeared at the hearing
and presented argument in support the pending motion. In
particular, counsel for respondent argued that the notice of
deficiency was mailed to petitioner's last known address in that
respondent's records indicate that petitioner's 1992 tax return
was the last return filed by petitioner prior to the mailing of
the notice of deficiency. Although petitioner did not appear at
the hearing, she 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
notice of deficiency to the taxpayer's "last known address".
Sec. 6212(b); Frieling v. Commissioner, 81 T.C. 42, 52 (1983).
If a notice of deficiency is mailed to the taxpayer at the
taxpayer's last known address, then actual receipt of the notice
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