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KENNEY v. COMMISSIONER

Docket No. 87417.

37 T.C. 1161 (1962)

EDWARD A. KENNEY AND ESTATE OF HELEN V. KENNEY, DECEASED, EDWARD A. KENNEY, SR., ADMINISTRATOR C.T.A., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 29, 1962.

Attorney(s) appearing for the Case

Jules I. Whitman, Esq., for the petitioners.

Malin VanAntwerp, Esq., for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in income tax due from petitioners for the years 1956, 1957, and 1958 in the respective amounts of $2,096.49, $4,984.28, and $1,626.86.

The issues for decision are:

(1) Whether this Court has jurisdiction over the proceeding, and this issue depends in turn upon whether respondent issued a valid statutory notice of deficiency to petitioners; and

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