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On January 28, 1998, petitioner left the United States for
Nassau, Bahamas. On January 30, 1998, respondent mailed the
statutory notice of deficiency (notice) to petitioner's home
address in California.
After learning of the notice, on April 28, 1998, petitioner
returned to the United States. According to the United States
postmark, petitioner mailed her petition to this Court on May 1,
1998--the 91st day after the notice was mailed. On May 5, 1998,
95 days after the notice was mailed, the Court received the
petition and stamped it filed. At the time she filed the
petition, petitioner resided in East Palo Alto, California.
Discussion
This Court's jurisdiction is strictly limited by statute,
and unless a petition is filed within the time prescribed by
statute, we lack jurisdiction and must dismiss the case. See
Estate of Moffat v. Commissioner, 46 T.C. 499, 501 (1966).
Ordinarily, a taxpayer has 90 days from the date the notice
is mailed within which to file a petition with this Court. See
sec. 6213(a). However, where a notice is "addressed to a person
outside the United States," the taxpayer has 150 days from the
date the notice is mailed in which to file a petition (the 150-
day rule). Id.
In this case, the 90-day period for filing a petition
expired on April 30, 1998. Petitioner did not mail her petition
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