Theolia Millsap - Page 7

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            a purported State income tax return for petitioner and Mrs.                                 
            Millsap for 1991, and purported Federal and State income tax                                
            returns for petitioner and Mrs. Millsap for 1988.  All of these                             
            documents list the East 11th Street address as the applicable                               
            address.  The remaining documents attached to petitioner's Rule                             
            50(c) statement include a purported Form 4868 (Application for                              
            Automatic Extension of Time to File U.S. Individual Income Tax                              
            Return) for 1988 (dated April 17, 1989) and 9 Forms 1099-MISC                               
            (with transmittal Form 1096) for Millsap Construction for 1989.5                            
            All of these remaining documents (except for those described                                
            supra note 5) list "114 N. Crossway St., Rome, Georgia 30161" as                            
            the applicable address.  See supra note 4.                                                  
                  The 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 Commissioner,                             
            after determining a deficiency, to send a notice of deficiency to                           
            the taxpayer by certified or registered mail.  It is sufficient                             
            for jurisdictional purposes if the Commissioner mails the notice                            

                  5  Three of the 9 Forms 1099 purportedly issued to a Terry                            
            Satterfield, a Joshua Watkins, and a Phil Johnson list as the                               
            recipients' address 12 Landrum Place, Rome, Georgia 30161; i.e.,                            
            the Landrum Place address.  Two of the remaining Forms 1099 list                            
            13 Landrum Place and 16 Landrum Place as the recipients' address.                           

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