T.C. Memo. 1997-465
UNITED STATES TAX COURT
LONE STAR LIFE INSURANCE COMPANY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 14781-96, 5898-97. Filed October 14, 1997.
Eleftherios Peter Baker, for petitioner.
Avery Cousins III and Anthony S. Gasaway, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: The case assigned
docket No. 14781-96 is before the Court on respondent's Motion
for Partial Summary Judgment and petitioner's Cross-Motion for
Summary Judgment. The issue to be decided is whether the period
of limitations expired prior to the issuance of the notice of
deficiency.
The case assigned docket No. 5898-97 is before the Court on
petitioner's Motion to Dismiss for Lack of Jurisdiction on the
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