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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,
1987).
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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