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Discussion
The Tax Court, like all Federal courts, is a court of
limited jurisdiction, and we may exercise our jurisdiction only
to the extent authorized by Congress. 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 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). If a notice of
deficiency is mailed to the taxpayer at the taxpayer's last known
address, actual receipt of the notice by the taxpayer is
immaterial. 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, supra at 52. The
taxpayer, in turn, has 90 days (or 150 days if the notice is
addressed to a person outside of the United States) from the date
that the notice of deficiency is mailed to file a petition in
this Court for a redetermination of the deficiency. Sec.
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