Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes - Page 6

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               In this case, the coexecutrixes of decedent’s estate filed a           
          notice of fiduciary relationship pursuant to section 6903.                  
          Section 6903 provides:                                                      
                    Upon notice to the Secretary that any person is                   
               acting for another person in a fiduciary capacity, such                
               fiduciary shall assume the powers, rights, duties, and                 
               privileges of such other person in respect of a tax                    
               imposed by this title (except as otherwise specifically                
               provided and except that the tax shall be collected                    
               from the estate of such other person), until notice is                 
               given that the fiduciary capacity has terminated.                      
          Once a notice of fiduciary relationship is filed, the fiduciary             
          steps into the shoes of the decedent, and any notice to which the           
          decedent might otherwise be entitled will be sufficient if                  
          furnished to the decedent’s fiduciary, unless and until notice is           
          given that the fiduciary relationship has been terminated.  Sec.            
          6903; see also sec. 301.6903-1, Proced. & Admin. Regs.                      
               There is no dispute in this case that, in a Form 56 mailed             
          to respondent on September 24, 1998, the estate timely notified             
          respondent pursuant to section 6903 that the estate fiduciaries’            
          address of record was the Wroxton Road address.  There is also no           
          dispute that, although the notice of estate tax deficiency bore             
          the Aspen address and the Wroxton Road address, respondent                  
          inexplicably did not mail the notice to the Wroxton Road address.           
          Instead, respondent mailed the original notice of estate tax                
          deficiency to the former residential address (the Aspen address)            
          of one of the fiduciaries and to the attorneys for the estate               

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