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determinations for the taxable years 1989 through 1992. On
October 23, 1996, petitioner supplemented his motions.
On October 25, 1996, respondent filed a Motion to Dismiss
for Lack of Jurisdiction in each docket. In her motions,
respondent asserts that the Court lacks jurisdiction because of
petitioner's failure to file his petitions within the 90-day
period prescribed in section 6213(a). In Responses filed to
petitioner's motions to restrain assessment and collection,
respondent contends that the Court lacks jurisdiction to grant
such relief in these cases.
In a Statement filed December 17, 1996, petitioner contends
that the notices of deficiency that were mailed to him on June
23, 1995, are null and void because respondent did not respond to
his letter dated July 6, 1995.
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 the 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
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