William M. Hezel - Page 4

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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.                                              
               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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