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