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pursuant to Rule 40.1 Respondent determined a Federal estate tax
deficiency of $2,532,269 with respect to the Estate of Isabelle
N. Greenwood (the estate). The estate contends that respondent
did not mail a notice of estate tax deficiency to the estate or,
if respondent did mail the notice, the notice was not mailed to
the estate’s last known address and was, therefore, invalid.
Background
Isabelle Greenwood (the decedent) resided in Houston, Texas,
when she died on August 25, 1998. The coexecutrixes of
decedent’s estate, Donna Norquist (Ms. Norquist) and Christine N.
Stamey (Mrs. Stamey),2 resided in Santa Fe, New Mexico, and
Houston, Texas, respectively, on the date the petition was filed
in this case.
On September 24, 1998, the estate mailed to respondent a
Form 56, Notice Concerning Fiduciary Relationship, designating
Ms. Norquist and Mrs. Stamey as coexecutrixes and 2115 Wroxton
Road, Houston, Texas 77005 (the Wroxton Road address), as the
fiduciary address.
On May 25, 1999, the estate timely filed Form 706, United
1All section references are to the Internal Revenue Code in
effect on the date of decedent’s death, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
2Ms. Norquist and Mrs. Stamey are the decedent’s daughters.
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Last modified: May 25, 2011