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and we have no reason to believe that a notice of deficiency was
issued for these years. Consequently, we will dismiss this case
for lack of jurisdiction with respect to the taxable years 1987,
1988, 1989, and 1994, on the ground that respondent did not issue
a notice of deficiency to petitioner for those years.
Taxable Years 1991, 1992, and 1993
Respondent asserts that she mailed a notice of deficiency to
petitioner for the taxable years 1991, 1992, and 1993 on August
24, 1995, and that we lack jurisdiction over those years on the
ground that petitioner failed to file a timely petition for
redetermination. Petitioner contends that a notice was not
mailed to his last known address, and that he never received the
notice. Respondent has the burden of establishing both the
existence of a notice of deficiency as well as the date of
mailing. Pietanza v. Commissioner, supra at 736.
Consistent with Pietanza v. Commissioner, supra, we conclude
that the U.S. Postal Service Form 3877 offered by respondent is
insufficient, standing alone, to establish that respondent mailed
the notice of deficiency in question to petitioner. Not only is
the notice of deficiency missing in this case, but respondent was
unable to provide the Court with any other Postal Service
records, such as Postal Service Form 3849, showing the delivery
or attempted delivery of the articles listed in respondent's
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