- 4 - 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'sPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011