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ESTATE OF KUNZE v. COMMISSIONER

Docket No. 16583-98.

78 T.C.M. 598 (1999)

T.C. Memo. 1999-344

Estate of Edward J. Kunze, Deceased, Carol Ann Hause, Executor v. Commissioner.

United States Tax Court.

Filed October 18, 1999.

Attorney(s) appearing for the Case

Robert J. Tootelian, Jr., for the petitioner. John O. Walsh, for the respondent.

MEMORANDUM OPINION

GALE, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction, on the ground that the petition was not filed by a taxpayer meeting the requirements of section 7430(c)(4)(A)(ii).1 The issue for decision is whether section 7430(c)(4)(D) applies in determining the net worth requirements for an estate seeking review under...

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