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442, supplementing 110 T.C. 172 (1998); Stoody v. Commissioner,
67 T.C. 643, 644 (1977), supplementing 66 T.C. 710 (1976).
The estate contends that the factual record in the
Memorandum Opinion is incomplete in its essential elements.
Essentially, the estate disagrees with the Court’s conclusions
about the facts of this case. In our Memorandum Opinion, we
considered and addressed the estate’s arguments, the testimony of
all of the witnesses, and all of the documentary evidence. The
estate has not demonstrated any manifest error of fact.
Furthermore, on the basis of the record, the estate’s
version of the “facts” misconstrues the facts of this case,
ignores certain facts, or takes them out of their context by
isolating events and looking at them in a vacuum. For example,
the estate claims that shortly after respondent offered, via
telephone, to settle the case by assigning a fair market value of
$1,124,410 to the limited partnership interest in issue,
respondent faxed a new “offer” for almost $125,000 less even
though the Appeals officer stated in the phone conversation with
the estate’s accountant that the fax would contain the Appeals
officer’s calculations regarding how he arrived at a fair market
value of $1,124,410. The estate’s contention that the estate’s
representatives believed the $1,000,000 figure contained in the
January 14, 2002, fax was an offer from respondent is contrary to
the facts of this case.
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