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 (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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