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February 20, 1997, and February 24, 1997, were both within 90
days of the date on which the IRS letter dated November 21, 1996,
was mailed to petitioners.
At no time did petitioners ever request Form 8626 (Agreement
to Rescind Notice of Deficiency) from respondent, nor did
petitioners ever execute such form and tender it to respondent.
At no time did any of respondent's agents ever proffer Form
8626 to petitioners or execute such form on behalf of respondent.
Discussion
The 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
the taxpayer by certified or registered mail. A notice of
deficiency is sufficient if it is mailed to the taxpayer at the
taxpayer's last known address. Sec. 6212(b)(1). Pursuant to
section 6213(a), the taxpayer has 90 days (or 150 days if the
notice is addressed to a person outside of the United States)
from the date that the notice of deficiency is mailed to file a
petition with the Court for a redetermination of the deficiency.
Section 6212(d) authorizes the Commissioner, with the
consent of the taxpayer, to rescind any notice of deficiency
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