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of $1,253. The issue for decision is whether respondent is
estopped from assessing the deficiency in income tax.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Decedent died on February
20, 1996, a resident of the State of Ohio. The executor of her
estate, Denise M. Harple, was a resident of Ohio at the time the
petition was filed.
Decedent and her former husband, Robert Severt,
electronically filed a joint Federal income tax return, dated
February 21, 1994, for the taxable year 1993. Robert Severt died
on February 12, 1995. Decedent was the sole beneficiary and
executrix of his estate, and she retained legal counsel to handle
the probate matter. On March 24, 1995, decedent, as executrix,
executed Form 4810, Request for Prompt Assessment Under Internal
Revenue Code Section 6501(d), with respect to Robert Severt's
taxable years 1992, 1993, 1994, and 1995. The request was
received by the Internal Revenue Service (IRS) on March 29, 1995.
By letter dated June 15, 1995, decedent was notified that Robert
Severt's returns for 1992 and 1993 had been accepted as filed.
Robert Severt's estate was closed in August 1995.
On February 21, 1996, respondent mailed a letter which
proposed changes to decedent and Robert Severt's 1993 tax return.
On July 2, 1996, respondent issued a notice of deficiency to
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