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Petitioner challenges the validity of the notice of
determination on the ground that it was not mailed to his
“correct address”. The record shows otherwise. Specifically,
the notice of determination was mailed to the same address that
petitioner listed as his return address both on his request for
an administrative hearing and in the petition that he filed with
the Court. Petitioner has not identified any other address to
which the notice of determination should have been mailed.
Accordingly, we conclude that the notice of determination was
mailed to petitioner at his last known address. See secs.
6320(a)(2)(C), 6330(a)(2)(C); see also Abeles v. Commissioner, 91
T.C. 1019, 1035 (1988); sec. 301.6212-2, Proced. & Admin. Regs.
Under the circumstances, the issue remaining for decision is
whether the petition was timely filed. The record shows that
respondent mailed the notice of determination to petitioner on
December 11, 2001. Consequently, the 30-day period for filing a
timely petition with the Court expired on Thursday, January 10,
2002, a date that was not a legal holiday in the District of
Columbia. The petition in this case was received and filed by
the Court on February 7, 2002, and arrived at the Court in an
envelope bearing a U.S. Postal Service postmark date of January
11, 2002. Because the petition was mailed to the Court one day
after the expiration of the 30-day filing period, it follows that
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