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ESTATE OF CALLAWAY v. COMMISSIONER

Docket No. 20048-96.

75 T.C.M. 1956 (1998)

T.C. Memo. 1998-99

Estate of James T. Callaway, Deceased, Elizabeth N. Callaway, Executrix, and Elizabeth N. Callaway v. Commissioner.

United States Tax Court.

Filed March 10, 1998.

Attorney(s) appearing for the Case

Frank Agostino, Hackensack, N.J., for the petitioners. Susan G. Lewis and Guy A. Bracuti, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This case is before the Court on petitioners' Motion for Summary Judgment. In addition, the Court, sua sponte, raised certain jurisdictional issues concerning the validity of the notices of deficiency at issue.1

The primary issue for consideration is whether the affected items notices of deficiency are valid. In this connection, we must consider whether the partnership...

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