- 10 - January 10, 2006, at 9 a.m. in San Antonio, Texas, in a designated courtroom in order to precede the scheduled trial of the case that week. Petitioner failed to make an appearance at the hearing. OPINION I. Jurisdiction There are two prerequisites to this Court’s jurisdiction to redetermine a deficiency: (1) The issuance of a valid notice of deficiency by the Commissioner, and (2) the timely filing of a petition with the Court by the taxpayer. See Rule 13(a), (c); Rochelle v. Commissioner, 116 T.C. 356, 358 (2001) (and cases cited thereat), affd. 293 F.3d 740 (5th Cir. 2002). Validity of Notice of Deficiency Petitioner contends that the notice of deficiency is invalid because it lists incorrectly the last date on which petitioner could file a timely petition with this Court. Petitioner relies on section 6213(a) and the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. 105-206, sec. 3463(a), 112 Stat. 767, for his argument that the notice of deficiency is invalid. Pursuant to section 6213(a), a taxpayer has 90 days (or 150 days if the notice is addressed to a person outside the United States) from the date that the notice of deficiency is mailed toPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: March 27, 2008