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ESTATE OF LEWIS v. COMMISSIONER

Docket Nos. 26501-87, 26502-87.

55 T.C.M. 22 (1988)

T.C. Memo. 1988-36

Estate of James F. Lewis, Jr., Deceased, James F. Lewis, III and Frank Appleby, Co-Executors v. Commissioner. Estate of Rosemary R. Lewis, Deceased, Frank Appleby, Successor Personal Representative v. Commissioner.

United States Tax Court.

Filed February 3, 1988.

Attorney(s) appearing for the Case

Aubrey J. Owen, 103 N. Braddock St., Winchester, VA, for the petitioners. Craig A. Etter, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:1

These cases are before the Court on petitioners' motions to dismiss. The issues before the Court are (1) whether respondent mailed notices of deficiency to petitioners and (2) whether, assuming notices were mailed, the notices were timely. The facts are not in dispute and are as follows.

Findings of Fact

At some point in time, James F. and...

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