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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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