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Our jurisdiction in this case depends on respondent's having
issued valid notices of deficiency. Frieling v. Commissioner, 81
T.C. 42, 46 (1983). Petitioner argues that the 9th Street
address was his last known address and that because the notices
were not mailed to the 9th Street address, they are invalid.
Proper mailing of a notice of deficiency to the taxpayer at his
last known address is sufficient to validate the notice whether
or not the taxpayer actually receives it. Sec. 6212(b)(1); see
Frieling v. Commissioner, supra at 48, 52, and cases cited
therein. It is well established, however, that even where the
Commissioner mails a notice to an address other than the
taxpayer's last known address, if the taxpayer receives the
notice within the period for filing a timely petition and in fact
files a timely petition, the Court has jurisdiction. Frieling v.
Commissioner, supra at 53.
Further, oral notice that a notice of deficiency has been
issued may be sufficient for jurisdictional purposes if the
taxpayer receives such notice in time to file, and does file, a
timely petition, even if the written notice of deficiency is not
sent to the last known address and the taxpayer does not receive
such written notice until after filing. Zaun v. Commissioner, 62
T.C. 278 (1974). In Zaun we held that a notice of deficiency was
valid for jurisdictional purposes, even assuming it was not sent
to the last known address, where the taxpayers received oral
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