- 2 - 6213(a).1 For the reasons stated below, we shall grant respondent’s motion. Background On August 3, 2006, respondent determined petitioner was liable for a deficiency of $3,532 for 2004 and issued a notice of deficiency to petitioner’s last known address. The notice of deficiency lists November 1, 2006, as the last date to petition the Court. Petitioner’s petition to redetermine respondent’s determination is dated November 21, 2006, and was received and filed by the Court on December 8, 2006. In her petition, petitioner states that she is aware that she missed the deadline for filing a petition with the Court, but she requests an extension. Petitioner resided in Newark, New Jersey, when the petition was filed. Discussion The jurisdiction of this Court depends on the timely filing of a petition. Rule 13(c). Section 6213(a) requires that petitioner’s petition to redetermine the deficiency be filed with the Court within 90 days after the notice of deficiency was mailed. The notice of determination was mailed to petitioner’s last known address by certified mail on August 3, 2006, and the 1 Section references are to the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 NextLast modified: November 10, 2007