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Discussion
This 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
at the taxpayer's "last known address". Sec. 6212(b); Frieling
v. Commissioner, 81 T.C. 42, 52 (1983). The taxpayer, in turn,
generally has 90 days 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).
There is no dispute that respondent mailed the notice of
deficiency to petitioner at her last known address on January 6,
2000. Accordingly, the 90-day period for filing a timely
petition with the Court expired on Wednesday, April 5, 2000. See
sec. 6213(a). The petition in this case was not filed until
April 7, 2000.
Although the petition was not timely filed, petitioner
maintains that the petition was mailed to the Court on April 5,
2000-–the 90th day after the mailing of the notice. Petitioner
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