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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). The taxpayer, in turn, has 90 days (or 150 days if the
notice is addressed to a person outside of the United States)
from the date the notice of deficiency is mailed to file a
petition in this Court for a redetermination of the deficiency.
Sec. 6213(a).
There is no dispute that respondent mailed a notice of
deficiency to petitioners for the taxable years 1994, 1995, and
1996 on February 19, 1998. Further, an employee of petitioners
received the notice of deficiency on February 20, 1998. The 90-
day period for filing a timely petition with the Court contesting
the notice of deficiency expired on Wednesday, May 20, 1998.
On June 9, 1998, the Court received an "Affidavit" from
petitioners, which the Court filed as a petition for
redetermination for the taxable years 1994, 1995, and 1996.
Although petitioners contend that the envelope that their
employee mailed to the Court by registered mail on February 20,
1998, contained a petition contesting the notice of deficiency at
issue, the record shows otherwise. In particular, the contents
of the envelope that petitioners mailed to the Court on February
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