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Specifically, petitioner told Ms. Russell that petitioner was not
going to claim her certified mail and that petitioner did not
care what disposition Ms. Russell made of such mail.
Petitioner mailed her petition to this Court on October 31,
1995, which petition was received and filed by the Court on
November 6, 1995. The petition includes allegations that (1)
petitioner was never served with notices of deficiency for the
taxable years 1989 through 1993; (2) petitioner was totally
unaware of any such notices until after the expiration of the
time for timely filing a petition with this Court in respect of
such notices; and that, as a consequence of the foregoing, (3)
petitioner was denied her right to contest such notices.
Subsequently, respondent filed her Motion to Dismiss for Lack of
Jurisdiction. Respondent contends that (1) notices of deficiency
for the taxable years 1989 through 1993 were issued to
petitioner; (2) such notices were mailed to petitioner at
petitioner's last known address and are therefore valid; and (3)
petitioner failed to file a timely petition for redetermination
with the Court in respect of such notices.
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 respondent,
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