United States Tax Court June 30, 1981, Docket No. 14010-79 (Manson Western Corp. v. Commissioner)

lead-opinion

OPINION

Tannenwald, Judge:

This case is before us on respondent’s motion to amend his answer to include allegations (1) that he timely mailed to petitioner a notification as described in section 534(b),1 and (2) that petitioner did not timely respond with a statement as described in section 534(c).

The facts relevant to the instant motion are not in dispute.