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indicate that either notice of deficiency was returned to
respondent by the Postal Service.
On December 6, 1999, respondent filed a supplement to
respondent's motion to dismiss. Respondent attached to the
supplement copies of petitioner’s timely filed income tax returns
(Forms 1040) for the 2 years in issue, both of which list the
Ulloa Street address as petitioner’s home address. Respondent
also attached to the supplement a copy of petitioner’s timely
filed income tax return (1040PC format) for 1996, which also
lists the Ulloa Street address as petitioner’s home address.
Finally, respondent attached to the supplement copies of
transcripts of computer records obtained in June 1997 showing
petitioner’s current address as the Ulloa Street address. In the
supplement, respondent acknowledges that at that time (i.e., in
June 1997) petitioner’s brother Gary Munoz informed respondent
that petitioner was stationed overseas in Korea on a military
assignment; however, respondent asserts that the brother was
unable to provide a forwarding address for petitioner.
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
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