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Discussion
The Court's jurisdiction to redetermine a deficiency depends
upon the issuance of a valid notice of deficiency and the filing
of a timely 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 of deficiency to the taxpayer's "last known
address". Sec. 6212(b); Frieling v. Commissioner, 81 T.C. 42, 52
(1983). If a notice of deficiency is mailed to the taxpayer at
the taxpayer's last known address, actual receipt of the notice
is immaterial. King v. Commissioner, 857 F.2d 676, 679 (9th Cir.
1988), affg. 88 T.C. 1042 (1987); Yusko v. Commissioner, 89 T.C.
806, 810 (1987); Frieling v. Commissioner, supra at 52. The
taxpayer, in turn, generally has 90 days from the date the notice
of deficiency is mailed to file a petition with the Court for a
redetermination of the deficiency. Sec. 6213(a).
There is no dispute in this case that the petition was not
filed within the 90-day period prescribed in section 6213(a).
Although respondent mailed the notice of deficiency in question
on January 30, 1984, the petition was not filed until February
24, 1998. Under the circumstances, it is evident that the Court
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