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ESTATE OF DiREZZA v. COMMISSIONER

Docket No. 16705-79.

78 T.C. 19 (1982)

ESTATE OF NERO DiREZZA, DECEASED, JAMES L. DIREZZA, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 11, 1982.

Attorney(s) appearing for the Case

Gene F. Reardon, for the petitioner.

W. Edward Williams and Thomas G. Hodel, for the respondent.

DAWSON, Judge:

In the statutory notice which he sent to petitioner, respondent determined an addition to tax under section 6651(a)(1)1 in the amount of $552 but did not determine any deficiency in Federal estate tax. The issues for decision are as follows:

(1) Whether this Court has jurisdiction to redetermine an addition for late filing attributable to an agreed additional tax liability if respondent sends a statutory notice...

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