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deficiency. Petitioner denies receiving any notices of
deficiency.
Following the hearing, respondent was provided a further
opportunity to produce a copy of the notice of deficiency for the
years 1991, 1992, and 1993, and/or any other evidence relevant to
the existence and disposition of the notice. In a status report,
respondent stated that she has searched her records and is unable
to locate a copy of the notice of deficiency in question. In
addition, respondent reported that the U.S. Postal Service was
unable to locate its records respecting certified mail or copies
of receipts for the period in question.
There is nothing in this record which reflects the amounts
of the deficiencies that were determined for 1991, 1992, and 1993
and no historical analysis of the examination. Respondent did
not present a witness in an attempt to analyze the transcript of
account and documents that were available or otherwise provide
testimony as to the procedures taken in the preparation and
issuance of a notice of deficiency for 1991 through 1993.
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
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