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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
assessment).
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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