10
6501(e)(2). Accordingly, since the parties have stipulated that
the statutory notice of deficiency herein was issued more than 3
years after the estate tax return was filed, such notice of
deficiency was barred by the statute of limitations.
Petitioner's motion for partial summary judgment will be granted.
An order granting petitioner's
motion for partial summary judgment
and a decision for petitioner will
be entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011