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ESTATE OF MOSS v. COMMISSIONER

Docket No. 7266-76.

37 T.C.M. 449 (1978)

T.C. Memo. 1978-99

Estate of Dana C. Moss, Marjorie H. Moss (now Wohlers), Executrix v. Commissioner.

United States Tax Court.

Filed March 9, 1978.

Attorney(s) appearing for the Case

James E. Bishop, Jack R. Givens, 201 W. 5th St., Tulsa, Okla., for the petitioner. James D. Thomas, for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $24,219.35. Both parties have moved that this case be dismissed for want of jurisdiction, respondent on the grounds that the petition was not timely filed,1 petitioner on the grounds that under section 62122 the statutory notice was invalid. The issue for decision is whether...

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