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HAROLD PATZ TRUST v. COMMISSIONER

Docket No. 5954-76.

69 T.C. 497 (1977)

HAROLD PATZ TRUST, CLIFFORD PATZ AND HOWARD PATZ, TRUSTEES, AND DARRELL PATZ TRUST, CLIFFORD PATZ AND HOWARD PATZ, TRUSTEES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 20, 1977.

Attorney(s) appearing for the Case

Robert E. Nelson, for the petitioners.

Joseph R. Peters and Joseph T. Chalhoub, for the respondent.

WILBUR, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction upon the ground that the petition was not filed by the proper parties as required by Rule 60(c).1 In addition, petitioners question the validity of the deficiency notices issued herein.

FINDINGS OF FACT

Petitioners are two intervivos trusts, the Harold Patz Trust (hereinafter...

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