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Urquhart).
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
dismiss.
Discussion
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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