the Secretary shall have no right to mail a further notice of deficiency to the taxpayer for the same taxable year. In McCue v. Commissioner, 1 T.C. 986 (1943), the Court construed a predecessor of that section, namely, section 272(f) of the Internal Revenue Code of 1939. There, the Commissioner mailed a notice of transferee liability to a taxpayer, and the taxpayer timely petitioned the Court with respect to the notice. See McCue v. Commissioner, 1 T.C. at 987. n Stamm Int'l Corp. v. Commissioner, 84 T.C. 248, 252 (1985), the Court cited McCue in support of the Court’s conclusion that “A valid petition is the basis of the Tax Court’s jurisdiction. To be valid, a petition must be filed from a valid statutory notice.” Accord Lone Star Life Ins. Co. v. Commissioner, T.C. Memo. 1997—465 (<HOLDING>). Petitioner seeks to invoke the Court’s
holding that a notice of deficiency was invalid where it was the second notice mailed for that year and the taxpayer timely petitioned the court as to the first notice holding that plaintiff complied with plain language of the notice requirement when notice was mailed within statutory period although it was not received until after holding that notice to the attorney of record constitutes notice to the petitioner holding that due process is satisfied where notice is mailed to the wrong address if the appellant received actual notice holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice