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Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Naftel v. Commissioner, 85 T.C. 527, 529 (1985). Our
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 the Commissioner 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 deficiency
notice is mailed to the taxpayer's last known address, actual
receipt of the notice is immaterial. King v. Commissioner, 857
F.2d 676, 679 (9th Cir. 1988), affg. 88 T.C. 1042 (1987); Yusko
v. Commissioner, 89 T.C. 806, 810 (1987); Frieling v.
Commissioner, supra at 52. The taxpayer, in turn, has 90 days
(or 150 days if the notice is addressed to a person outside of
the United States) from the date the notice of deficiency is
mailed to file a petition in this Court for a redetermination of
the deficiency. Sec. 6213(a).
Respondent issued a notice of deficiency to petitioner for
1992 on February 22, 1995. The petition was filed nearly 1 year
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