Nanci A. Bernard - Page 5




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          income tax returns, Forms 1040, for 1998 and 1999.  The 1998                
          return, which was filed in April 1999, lists the Grasonville                
          address as petitioner’s then current address; in contrast, the              
          1999 return, which was filed in April 2000, lists the Baltimore             
          address as petitioner’s then current address.                               
               At the hearing, petitioner stated that she moved from the              
          Grasonville address to the Baltimore address in late November               
          1999 and that she moved from the Baltimore address to the                   
          Pasadena address in December 2000.                                          
          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.  A notice of deficiency is sufficient if it is             
          mailed to the taxpayer at the taxpayer's last known address.  See           
          sec. 6212(b)(1).  If the notice is mailed to the taxpayer at the            
          taxpayer's last known address, actual receipt of the notice by              
          the taxpayer is immaterial.  See King v. Commissioner, 857 F.2d             
          676, 679 (9th Cir. 1988), affg. 88 T.C. 1042 (1987); Yusko v.               
          Commissioner, 89 T.C. 806, 810 (1987); Frieling v. Commissioner,            





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