ESTATE OF MITCHELL v. COMMISSIONER

Docket No. 21805-93.

103 T.C. 520 (1994)

ESTATE OF PAUL MITCHELL, DECEASED, PATRICK T. FUJIEKI, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 26, 1994.


Attorney(s) appearing for the Case

B. John Williams, Jr., David W.K. Wong, and Margery S. Bronster, for petitioner.

Henry E. O'Neill, for respondent.


OPINION

JACOBS, Judge:

This matter is currently before the Court on petitioner's motion for summary judgment pursuant to Rule 121.1 Petitioner claims that the statute of limitations bars the assessment of additional Federal estate tax and penalties. For the reasons that follow, we hold that the notice of deficiency was timely mailed.

Background

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