Estate of Isabelle N. Greenwood, Deceased, Donna Norquist and Christine N. Stamey, Independent Co-Executrixes - Page 8

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          printed next to the Aspen address,6 but respondent concedes that            
          he did not mail the notice to the Wroxton Road address.                     
          Respondent mailed the notice only to one coexecutrix, Ms.                   
          Norquist, at the Aspen address.  According to the estate,                   
          respondent’s failure to mail the notice to the Wroxton Road                 
          address constituted “a fundamental failure to comply with Section           
               Respondent contends that his mailing, while flawed, was                
          sufficient on the facts involved here to comply with section                
          6212(a).  Respondent argues that section 6212(a) requires a                 
          mailing to the estate which either was sent to the estate’s last            
          known address or, if sent to an incorrect address, was actually             
          received by the estate in sufficient time to meet the deadline              
          for filing a petition in this Court.  Respondent contends that              
          the latter requirement was satisfied because the estate actually            
          filed a petition with this Court prior to the expiration of the             
          filing period.  We agree with respondent.                                   
               The purpose of the mailing under section 6212 is to provide            
          the taxpayer with notice and an opportunity to petition the Court           
          to challenge the Commissioner’s determination of a deficiency.              
          Frieling v. Commissioner, 81 T.C. at 53; Reddock v. Commissioner,           
          supra at 25; Lifter v. Commissioner, 59 T.C. 818, 820 (1973);               

               6Respondent’s use of the Aspen address for Ms. Norquist and            
          the Wroxton Road address for Mrs. Stamey reflected the                      
          fiduciaries’ addresses as they appeared on the estate tax return.           

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