Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes - Page 5

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          requirements for our jurisdiction in a deficiency case are a                
          valid notice of deficiency issued by the Commissioner and a                 
          timely petition filed by the taxpayer.  Frieling v. Commissioner,           
          81 T.C. 42, 46 (1983).  Because the estate timely filed its                 
          petition in this case, the only jurisdictional issue for our                
          consideration is the validity of the notice of deficiency.                  
               If the Commissioner determines that there is a deficiency in           
          estate tax, he is authorized to send notice of such deficiency              
          “to the taxpayer by certified mail or registered mail.”  Sec.               
          6212(a); see also Abeles v. Commissioner, 91 T.C. 1019, 1026                
          (1988).5  Section 6212(b) authorizes the Commissioner to use                
          certain addresses in mailing the notice of deficiency.  Section             
          6212(b)(3), which deals solely with the estate tax, provides                
          that, in the absence of a notice concerning fiduciary                       
          relationship filed under section 6903, a notice of estate tax               
          deficiency addressed and mailed to the decedent at the decedent’s           
          last known address is sufficient for purposes of chapter 11                 
          (dealing with the estate tax) and chapter 63 (dealing with                  

               5The mailing of a notice under sec. 6212(a) suspends the               
          running of the 3-year limitations period for assessments (the               
          limitations period) and triggers the taxpayer’s right to petition           
          this Court for redetermination of the deficiency.  Secs. 6213(a),           
          6503(a)(1); see also St. Joseph Lease Capital Corp. v.                      
          Commissioner, 235 F.3d 886, 888-889 (4th Cir. 2000) (holding that           
          in order to suspend the limitations period, the mailing need                
          comply only with section 6212(a)), affg. T.C. Memo. 1996-256.               

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