- 3 -
6020(b). Based upon information provided by third parties,
respondent determined that petitioner had taxable income in both
years. Accordingly, respondent determined deficiencies in
petitioner's 1983 and 1984 Federal income taxes in the respective
amounts of $1,777 and $1,442, and additions to tax for such
years. The notices of deficiency were computer generated at
respondent's service center in Ogden, Utah. Respondent mailed
notices of deficiency for taxable years 1983 and 1984 by
certified mail addressed to petitioner at 1865 N.W. 106th,
Portland, Oregon, on June 12, 1989. The notices of deficiency
were returned to respondent's Ogden Service Center with the
envelopes marked "Unclaimed".
It is not clear from the record when petitioner learned of
the asserted deficiencies. The envelope in which the petition
for redetermination was received by the Court was postmarked June
14, 1995, and the petition was filed with the Court on June 19,
1995.
Section 6212(a) authorizes the Secretary or his delegate,
upon determining that there is a deficiency in income tax, to
send a notice of deficiency "to the taxpayer by certified mail or
registered mail." A notice of deficiency is valid, regardless of
actual receipt by the taxpayer, if it is mailed to the taxpayer's
"last known address." King v. Commissioner, 857 F.2d 676, 679
(9th Cir. 1988), affg. 88 T.C. 1042 (1987). Neither section 6212
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