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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.
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Last modified: November 10, 2007