Estate of Marguerite M. Cranor, Deceased, John R. Phillips, Jr., Administrator ad Litem - Page 2

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               Winston S. Evans and J. Allen Reynolds III, for petitioner.            
               Robert B. Nadler, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  This case is before the Court on                       
          respondent’s motion to dismiss for lack of jurisdiction on the              
          ground that the petition was not filed within the time prescribed           
          by section 6213(a) or section 7502.  We hold that the petition              
          was timely filed because it was timely sent.  See sec. 7502(a),             
          (f).  Thus, we will deny respondent’s motion.                               
               Section references are to the Internal Revenue Code in                 
          effect for 1999.                                                            
          A.   Petitioner and the Notice of Deficiency                                
               John R. Phillips, Jr., is the administrator ad litem of the            
          Estate of Marguerite M. Cranor, Deceased (decedent).  Decedent              
          died a resident of Tennessee, and her will was probated in                  
          Tennessee.  The administrator ad litem lived in Gallatin,                   
          Tennessee, when the petition was filed.                                     
               On June 8, 1999, respondent sent a notice of deficiency by             
          certified mail to petitioner in which respondent determined an              
          estate tax deficiency of $317,280.  The 90th day after the notice           
          of deficiency was issued was September 6, 1999, which was a legal           
          holiday (Labor Day) in the District of Columbia.  Therefore,                

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