T.C. Memo. 1999-115
UNITED STATES TAX COURT
ESTATE OF CHARLES B. GRANT, JR., DECEASED,
CHARLES B. GRANT, III, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13427-98. Filed April 6, 1999.
Jo Karen Parr, for petitioner.
Linda K. West, for respondent.
MEMORANDUM OPINION
GERBER, Judge: We consider here petitioner’s motion to
amend the petition. Respondent has objected on the ground that
the subject matter of the proposed amendment is not relevant. We
therefore consider whether the relevance of the matter pleaded is
prerequisite to our granting leave to amend a pleading.
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