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ESTATE OF QUIRK v. COMMISSIONER

Docket No. 8428-72.

60 T.C. 520 (1973)

ESTATE OF HELEN MOORE QUIRK, AKELEY P. QUIRK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 28, 1973.

Attorney(s) appearing for the Case

Hilbert P. Zarky, for the petitioner.

St. Clair Reeves, for the respondent.

OPINION AND ORDER

FORRESTER, Judge:

Respondent has moved for leave to file his answer out of time. The motion itself was untimely and petitioner opposes it, relying in part on an unreported Memorandum Sur Order filed by this Court on July 18, 1972, in Clark Tank Lines Company, Inc., docket No. 721-71.

In a notice of deficiency dated November 1, 1972, and addressed to petitioner in Los Angeles, Calif., respondent determined an estate tax deficiency...

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