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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.
Discussion
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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