Estate of James T. Callaway, Deceased, Elizabeth N. Callaway, Executrix, and Elizabeth N. Callaway - Page 3

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          respecting the partnership's 1988 taxable year.  Respondent has             
          been unable to provide the Court with copies of the NBAP's                  
          purportedly mailed to decedent on the same date with respect to             
          the partnership's 1986 and 1987 taxable years.                              
               On December 23, 1991, Mrs. Callaway forwarded several                  
          letters to respondent, including a request for prompt assessment            
          of income tax submitted on behalf of decedent's estate for the              
          taxable years 1983 through 1990.  See sec. 6501(d).  In addition,           
          Mrs. Callaway remitted three checks to respondent in the amounts            
          of $90,635, $48,846, and $8,439 designated as deposits in the               
          nature of a cash bond respecting petitioners' tax liabilities for           
          1986, 1987, and 1988, respectively.  At the same time, Mrs.                 
          Callaway filed a Form 872-T with respondent, covering the taxable           
          years 1983 through 1990, along with a letter dated December 23,             
          1991, stating:                                                              
               please accept this form as a statement disclaiming and                 
               denying the Tax Matters Partners' settlement authority,                
               a statement denying the Tax Matters Partner's authority                
               to extend any statutes of limitation, and an election                  
               to have any items which would be classified as                         
               partnership items classified as non-partnership items                  
               subject to the deficiency procedures of Internal                       
               Revenue Code section 6213. * * *                                       
          There is no indication that respondent replied to Mrs. Callaway's           
          letters.  However, the record indicates that respondent initially           
          concluded that Mrs. Callaway's request for prompt assessment of             
          income tax filed on behalf of decedent's estate was invalid.                

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