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deficiency to a taxpayer (see sec. 6212(a)3) and that taxpayer’s
filing with this Court a timely petition that we redetermine the
deficiency determined against that taxpayer in that notice of
deficiency (see sec. 6213(a)4). See Normac, Inc. & Normac,
International v. Commissioner, 90 T.C. 142, 147 (1988).
Accordingly, if respondent issued a valid notice of deficiency
3Sec. 6212 provides, in pertinent part, as follows:
SEC. 6212. NOTICE OF DEFICIENCY.
(a) In General.--If the Secretary determines that there
is a deficiency in respect of any tax imposed by subtitle A
[relating to income taxes] * * * he is authorized to send
notice of such deficiency to the taxpayer by certified mail
or registered mail.
(b) Address for Notice of Deficiency.--
(1) Income and gift taxes and certain excise
taxes.--In the absence of notice to the Secretary under
section 6093 of the existence of a fiduciary
relationship, notice of a deficiency in respect of a
tax imposed by subtitle A * * *, if mailed to the
taxpayer at his last known address, shall be sufficient
for purposes of subtitle A * * * and this chapter
[chapter 63, relating to assessment] * * *
4Sec. 6213(a) provides, in pertinent part, as follows:
SEC. 6213. RESTRICTIONS APPLICABLE TO DEFICIENCIES;
PETITION TO TAX COURT.
(a) Time for Filing Petition and Restriction on
Assessment.--Within 90 days * * * after the notice of
deficiency authorized in section 6212 is mailed * * *, the
taxpayer may file a petition with the Tax Court for a
redetermination of the deficiency. * * *
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