Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes - Page 2

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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.                
               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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