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ESTATE OF ROSKI v. COMMISSIONER

Docket No. 5639-05.

128 T.C. 113 (2007)

128 T.C. No. 10

ESTATE OF EDWARD P. ROSKI, SR., DECEASED, EDWARD P. ROSKI, JR., EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 12, 2007.

Attorney(s) appearing for the Case

Robert T. Carney, for petitioner.

Scott A. Hovey, for respondent.

OPINION

GOEKE, Judge:

This matter is before the Court on the parties' cross-motions for summary judgment under Rules 121(a) and 217(b)(2).1

Respondent issued a notice of determination denying the Estate of Edward P. Roski (the estate) the election to pay Federal estate tax in installments under section 6166. The issues before us are: (1) Whether this Court's jurisdiction under section 7479 includes reviewing respondent...

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