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addressed to petitioner or her husband because she "only received
mail at her post office box".
Petitioner's second witness, Melinda Hayes (Hayes),
testified that she, her mother, and her brother resided at the
Bell Avenue address from December 1983 until June 1984.
Accordingly, Hayes allegedly was living at the Bell Avenue
address when the notice of deficiency was issued to petitioner.
Hayes testified that during the time she claims she resided at
the Bell Avenue address, she never received any mail that was
addressed to petitioner or her husband. Hayes claimed that her
family actually received mail at the Bell Avenue address. At the
time of the hearing, Hayes was petitioner's daughter-in-law.
Discussion
The jurisdiction of this Court is governed by statute. Sec.
7442. A valid notice of deficiency and a timely filed petition
are essential to our deficiency jurisdiction. Secs. 6212 and
6213; Rule 13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27
(1989); Abeles v. Commissioner, 91 T.C. 1019, 1025 (1988). Under
section 6212, a notice of deficiency is sufficient if it is
mailed to the taxpayer's last known address by certified or
registered mail. Sec. 6212(a) and (b). "A notice of deficiency
is valid if it is mailed to the taxpayer's last known address
even if it is not received by the taxpayer." Williams v.
Commissioner, 935 F.2d 1066, 1067 (9th Cir. 1991), affg. T.C.
Memo. 1989-439; King v. Commissioner, 857 F.2d 676, 681 (9th Cir.
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