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ESTATE OF GREENWOOD v. COMMISSIONER

Docket No. 12214-02.

85 T.C.M. 1117 (2003)

T.C. Memo. 2003-98

Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes v. Commissioner.

United States Tax Court.

Filed April 9, 2003.

Attorney(s) appearing for the Case

Edward D. Urquhart, John W. Porter, and Stephanie Loomis-Price, for the petitioners.

Lillian D. Brigman, for the respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This case is before the Court on the estate's motion to dismiss for lack of jurisdiction filed pursuant to Rule 40.1 Respondent determined a Federal estate tax deficiency of $2,532,269 with respect to the Estate of Isabelle N. Greenwood (the estate). The estate contends that respondent did not mail a notice of estate tax deficiency to the estate or, if respondent did mail the notice, the notice...

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