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department at the Atlanta Service Center during the period in
question.
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 a taxpayer by certified or registered mail. It
is sufficient for jurisdictional purposes if the Commissioner
mails the notice of deficiency to the taxpayer at 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, 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 under circumstances not present herein) from the
date that the notice of deficiency is mailed to file a petition
with this Court for a redetermination of the deficiency. Sec.
6213(a).
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