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ESTATE OF YOUNG v. COMMISSIONER

Docket No. 29433-81.

81 T.C. 879 (1983)

ESTATE OF SETH EDWARD YOUNG, JR., DECEASED, HAYDEN HABY, SR., AND SETH EDWARD YOUNG, SR., COEXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 17, 1983.

Attorney(s) appearing for the Case

Elwood Cluck, for the petitioners.

John F. Eiman, for the respondent.

OPINION

DAWSON, Chief Judge:

This case is before us on the Court's own motion to dismiss for lack of jurisdiction as to one of the additions to tax determined by respondent in the notice of deficiency. The issue for decision is whether under the facts herein this Court has jurisdiction to redetermine the addition to tax for late payment under section 6651(a)(2).1

Seth Edward...

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