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ESTATE OF SCARANGELLA v. COMMISSIONER

Docket No. 8741-72.

60 T.C. 184 (1973)

ESTATE OF ANNUNZIATA M. SCARANGELLA, DECEASED (INTESTATE), BY FRANK SCARANGELLA, ANTHONY SCARANGELLA, ANNETTE KENZIK, ROSE GRAY, ELVIRA DANIEL AND ALMERINTA BELLI (BY HER GUARDIAN JOSEPH BELLI), HEIRS-AT-LAW, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 1973.

Attorney(s) appearing for the Case

Geoffrey Lebar, for the petitioners.

Andrew S. Coxe and Lyndon J. Parker, for the respondent.

OPINION

DRENNEN, Judge:

Respondent has moved to dismiss the petition for lack of jurisdiction. The ground stated for his motion is that no determination of a deficiency has been made in this case. Petitioners counter with the assertion that a deficiency has been determined and that they have in fact received notice thereof, from which their petition was filed. The dispute between the parties centers around whether a statutory notice of deficiency...

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