Jean Mathia and Estate of Doyle V. Mathia, Deceased, Jean Mathia, Personal Representative - Page 1

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                                  T.C. Memo. 2007-4                                   


                               UNITED STATES TAX COURT                                


                JEAN MATHIA AND ESTATE OF DOYLE V. MATHIA, DECEASED,                  
                JEAN MATHIA, PERSONAL REPRESENTATIVE, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16483-05L.            Filed January 8, 2007.                


               Mark W. Curnutte, for petitioners.                                     
               Ann L. Darnold, for respondent.                                        


                                 MEMORANDUM OPINION                                   

               MARVEL, Judge:  This matter is before the Court on                     
          respondent’s Motion for Relief From Stipulations pursuant to Rule           
          91(e)1.                                                                     


               1All section references are to the Internal Revenue Code,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.