T.C. Memo. 1998-99
UNITED STATES TAX COURT
ESTATE OF JAMES T. CALLAWAY, DECEASED, ELIZABETH N.
CALLAWAY, EXECUTRIX, and ELIZABETH N. CALLAWAY, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20048-96. Filed March 10, 1998.
Frank Agostino, for petitioners.
Susan G. Lewis and Guy A. Bracuti, for 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
1 Section references are to the Internal Revenue Code, as
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