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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); Abeles v. Commissioner, 91 T.C. 1019, 1025
(1988). Section 6212(a) 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). Once the notice
of deficiency has been mailed, the taxpayer has 90 days (150 days
if addressed to a person outside the United States) in which to
file a petition in this Court. Sec. 6213(a).
Petitioner claims that he did not receive the notice of
deficiency until December 8, 1995. Petitioner further contends
that the notice of deficiency is "void" because the notice was
not mailed to his last known address, and it was undated.
In his opposition to respondent's motion, petitioner claims
that he has never been in the Federal Correctional Institution,
Three Rivers, Texas. Rather, he states that he has been "at all
times" incarcerated in the Federal Prison Camp, Tilden, Three
Rivers, Texas. Petitioner argues that his correct mailing
address is as follows: Federal Prison Camp, Tilden, P.O. Box
4300, Three Rivers, Texas 78071. Petitioner also argues that the
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