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1993 was sent to petitioner’s last known address. The 90-day
period for timely filing a petition with this Court regarding
this notice of deficiency expired on January 11, 1996. A notice
of deficiency for 1994 and 1995 was mailed to petitioner’s last
known address on July 25, 1997. The 90-day period for timely
filing a petition with this Court regarding this notice of
deficiency expired on October 23, 1997. Petitioner received
these notices of deficiency but did not file timely petitions
with regard to either notice of deficiency. As a result,
respondent assessed the deficiencies determined in those
notices.2
On February 1, 1999, a Final Notice-Notice of Intent to Levy
and Notice of Your Right to a Hearing was sent to petitioner
regarding unpaid income taxes for 1994 and 1995. The notice did
not pertain to petitioner’s 1993 income tax, and petitioner has
no unpaid tax with respect to 1993. The notice contained the
following pertinent information:
FINAL NOTICE
NOTICE OF INTENT TO LEVY AND NOTICE OF
YOUR RIGHT TO A HEARING
2To the extent that the petition in this case could possibly
be construed as a petition to the notices of deficiency, dated
Oct. 13, 1995 (for the taxable year 1993), and July 25, 1997 (for
the taxable years 1994 and 1995), the petition is obviously not
timely. Sec. 6213 generally allows taxpayers 90 days from the
date of the notice of deficiency in which to file a petition.
Our jurisdiction with respect to a notice of deficiency is
dependent upon a timely petition. See sec. 6213; Goza v.
Commissioner, 114 T.C. 176 (2000).
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