Estate of James T. Callaway, Deceased, Elizabeth N. Callaway, Executrix, and Elizabeth N. Callaway - Page 6

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          respondent conceded that all assessments entered against                    
          decedent's estate were improper on the ground that Mrs.                     
          Callaway's request for prompt assessment filed on behalf of                 
          decedent's estate on December 23, 1991, was valid, thereby                  
          resulting in the immediate conversion of decedent's Mountain View           
          partnership items to nonpartnership items under section                     
          6231(c)(2) and section 301.6231(c)-8T, Temporary Proced. & Admin.           
          Regs., 52 Fed. Reg. 6794 (Mar. 5, 1987).3  In contrast,                     
          respondent maintained that the July 1996 assessments entered                
          against Mrs. Callaway were proper on the ground that,                       
          notwithstanding the conversion of decedent's partnership items to           
          nonpartnership items, Mrs. Callaway continued to be treated as a            
          Mountain View partner pursuant to section 301.6231(a)(2)-1T(a),             
          Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5,                
               Following a hearing on the matter, we denied petitioners'              
          motion to restrain collection on the ground that the Court's                
          jurisdiction in this case is limited to a redetermination of the            
          additions to tax determined in the notices of deficiency for                
          affected items at issue, and, therefore, the Court lacks the                

          3  As a result of respondent's concession respecting the                    
          validity of the request for prompt assessment filed on behalf of            
          decedent's estate, respondent further concedes that respondent              
          was obliged to issue a notice of deficiency to decedent's estate            
          for (or assess) any deficiencies attributable to decedent's                 
          distributive share of Mountain View's partnership items for 1986,           
          1987, and 1988 by June 23, 1992.  See secs. 6501(d), 6229(f).               

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