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ESTATE OF FRY v. COMMISSIONER

Docket No. 26361-83.

88 T.C. 1020 (1987)

ESTATE OF WILLIAM F. L. FRY, DECEASED, DAUPHIN DEPOSIT BANK & TRUST COMPANY, COEXECUTOR, AND GRACE H. FRY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 22, 1987.

Attorney(s) appearing for the Case

Michael J. Egan, for the petitioners.

Melvin E. Lefkowitz, for the respondent.

OPINION

WHITAKER, Judge:

Respondent determined a deficiency in the Federal income tax liability of Mr. William F.L. Fry and his wife Mrs. Grace H. Fry for their calendar year 1976 in the amount of $840,298.18.1 This case is before the Court on petitioners' motion for partial summary judgment which raises the issue as to the timeliness of issuance of the statutory notice. The statutory notice is dated June 20, 1983, which...

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