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points in another direction, in this case we agree with the
Commissioner that it is appropriate to use an analogy to our
long-followed procedure in deficiency cases. That procedure, as
described in Nordstrom v. Commissioner, 50 T.C. 30, 32 (1968), is
to file an order requiring both parties
to furnish the Tax Court, insofar as
ascertainable and to the best of their
abilities, the names and addresses of the
heirs at law of the decedent, under the law
of the jurisdiction wherein the decedent was
a resident when his death occurred
and for the Court to then notify the heirs. Id.
We think this is the most reasonable procedure in the
absence of a statute or regulation providing differently. To
enable the parties to search for heirs, this case will be
continued,
And an appropriate order will
be issued.
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Last modified: November 10, 2007