OPINION
SIMPSON, Judge:
This matter is before us on the parties' cross motions to dismiss for lack of jurisdiction. The petitioner claims that the notice of deficiency was invalid because it was not mailed to the last known address of the estate or to the proper estate representative. The Commissioner claims that the petition was not filed within 90 days after the mailing of the notice of deficiency. Sec. 6213(a), I.R.C. 1954.
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