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Petitioner’s objection states in pertinent part as follows:
Enclosed postal receipt shows that the U.S. Postal
service had difficulty in contacting Mr. Schake.[3]
Therefore notice was not sent to my current address.
It was sent to my mother’s address, and I didn’t
receive the notice until Jan 8th 2002.
I called the court and they said I had time to file for
a hearing. At this time I was living in the country
sixteen miles for the nearest postal service. When it
was time to mail in the petition there was a severe
winter storm and the roads were closed Jan. 9th and
10th. I contacted the court and they allowed me a
grace period due to the impossible road conditions.
Respondent filed a response to petitioner’s objection
asserting that the notice of determination was mailed to
petitioner’s last known address.
This matter was called for hearing at the Court’s motions
session held in Washington, D.C. Counsel for respondent appeared
at the hearing and offered argument in support of the motion to
dismiss. There was no appearance by or on behalf of petitioner.
Discussion
The Tax Court 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 under sections 6320 and 6330 depends on
the issuance of a notice of determination and the filing of a
timely petition for review. See Sarrell v. Commissioner, 117
3 No postal receipt or other exhibit was enclosed with, or
attached to, petitioner’s objection as received by the Court.
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