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"last known address." Sec. 6212(b); Frieling v. Commissioner, 81
T.C. 42, 52 (1983). The taxpayer, in turn, 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 in this Court for a redetermination of the
deficiency. Sec. 6213(a).
There is no dispute that respondent mailed the notices of
deficiency to petitioner at his last known address on June 23,
1995. Further, petitioner admits that he received the notices of
deficiency and, in early July 1995, returned them to respondent
marked "Refusal For Cause Without Dishonor U.C.C. 3-501".
Petitioner did not file his petitions for redetermination with
the Court until September 25, 1996--some 15 months after the
notices of deficiency were mailed. Thus, it is evident that
petitioner did not timely file his petitions for redetermination.
Consequently, we will dismiss these cases for lack of
jurisdiction on the ground that petitioner failed to file his
petitions within the 90-day time period prescribed in section
6213(a).2
2 Although petitioner cannot pursue his case in this Court,
he is not without a remedy. In short, petitioner may pay the
tax, file a claim for refund with the Internal Revenue Service,
and if the claim is denied, sue for a refund in the Federal
District Court or the U.S. Court of Federal Claims. See
McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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