Stanley D. and Rosemary A. Clough - Page 6




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          delivered to him by Ogden Service Center personnel.  Mr. Holt’s             
          declaration outlines the procedures that he follows in processing           
          certified mail, including his practice of verifying the                     
          information contained in the Commissioner’s certified mail lists,           
          and, thereafter, placing a postmark stamp on each such list.  Mr.           
          Holt’s declaration states that, on December 4, 2001, he placed a            
          postmark stamp on the certified mail list that was attached as an           
          exhibit to respondent’s motion to dismiss.  Petitioners also                
          object to the admission of Mr. Holt’s declaration on the ground             
          that the document constitutes inadmissible hearsay.                         
                                     Discussion                                       
               The Tax Court is a court of limited jurisdiction, and we may           
          exercise our jurisdiction only to the extent authorized by                  
          Congress.  Sec. 7442; Judge v. Commissioner, 88 T.C. 1175, 1180-            
          1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985).               
          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); 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 a               
          taxpayer by certified or registered mail.  Pursuant to section              
          6213(a), a taxpayer has 90 days (or 150 days if the notice is               
          addressed to a person outside of the United States) from the date           






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