Nicholas O. Bachynsky - Page 4

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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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