- 5 - Mr. Selter appeared at the hearing and offered argument in respect of the pending motion. Mr. Selter informed the Court that he had contacted Ms. Hunt and that she had agreed to appear at the hearing. However, Mr. Selter failed to issue a subpoena to Ms. Hunt, and she did not appear to testify. However, the office manager of Mr. Selter’s firm did appear and testify. Also, during the hearing, Mr. Selter offered as an exhibit an article titled "Postal Service Gives 'Check in the Mail' A Whole New Twist", published in the New York Times on July 28, 2000. Respondent objected to the admission of the article on the ground that it was hearsay. The Court deferred ruling on the admissibility of the article. Discussion The Court's jurisdiction to redetermine a deficiency depends upon the issuance of a valid notice of deficiency and a timely filed petition. Rule 13(a), (c); see 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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