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call with the parties on July 30, 2002, at which time petitioners
stated that they agreed with the facts as set forth above.
Discussion
The 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 generally is sufficient if it is mailed to
the taxpayer's last known address. See sec. 6212(b)(1). In
turn, the taxpayer has 90 days (or 150 days if the notice is
addressed to a person outside the United States) from the date
that the notice is mailed to file a petition for redetermination
of the deficiency. See sec. 6213(a).
Section 7502, which sets forth the so-called timely
mailing/timely filing rule, generally provides that, if a
petition is filed with the Court after the expiration of the
statutory 90-day filing period, it is nevertheless deemed to be
timely filed if the date of the U.S. Postal Service postmark
stamped on the envelope bearing the petition is on or before the
last date for filing the petition. See sec. 7502(a)(1), (c)(2);
sec. 301.7502-1, Proced. & Admin. Regs. Section 7502(f) provides
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