Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes - Page 4

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               On May 8, 2002, respondent mailed by certified mail a notice           
          of estate tax deficiency (the notice) in an envelope addressed to           
          the estate and Ms. Norquist at the Aspen address.  The record is            
          not clear as to what became of the notice sent to the Aspen                 
          address.4  On its face, the notice was also addressed to Mrs.               
          Stamey at the Wroxton Road address, but respondent did not mail a           
          copy to Mrs. Stamey.                                                        
               Additionally, on May 8, 2002, respondent mailed copies of              
          the notice to Ms. Hardiman and Mr. Urquhart.  Both Ms. Hardiman             
          and Mr. Urquhart received their copies.                                     
               The estate filed a timely petition with this Court on July             
          24, 2002.  On the same day, the estate filed a motion to dismiss            
          for lack of jurisdiction to which respondent objected on                    
          September 19, 2002.  The Court held a hearing on the motion to              
          dismiss at the Court’s trial session in Houston, Texas, on                  
          October 22, 2002.  Counsel for the estate and respondent appeared           
          at the hearing and presented their positions on the motion to               
               The estate argues that we lack jurisdiction.  The two                  

               4The estate claims that it did not receive the notice of               
          deficiency from respondent.  Respondent acknowledges that he did            
          not remail the notice to the estate at the Wroxton Road address             
          or at any other address.                                                    

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