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of deficiency dated October 28, 1998, had been returned to
respondent undelivered. No appearance was made by or on behalf
of petitioner at the hearing.
Discussion
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. See Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
The Court's jurisdiction to redetermine a deficiency depends upon
the issuance of a valid notice of deficiency and a timely filed
petition. See 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)(1); 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. See sec. 6213(a).
The record in this case shows that respondent mailed a
notice of deficiency to petitioner for the 1996 taxable year on
October 28, 1998. However, the petition in this case was not
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