T.C. Memo. 1995-590
UNITED STATES TAX COURT
ESTATE OF GOLDA E. RIXON KOKERNOT, DECEASED,
MARY ANN K. LACY, EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16088-94. Filed December 13, 1995.
Before trial, the parties negotiated a settlement
specifying the manner of resolving all issues raised in
R's notice of deficiency. During discussions regarding
the proposed stipulated decision document, P sought to
raise an issue as to its entitlement to use the special
use valuation provisions of sec. 2032A, I.R.C. This
issue was not covered in R's notice of deficiency, and
was not raised or preserved by P in the pleadings or
the stipulated settlement agreement. Held: The issue
raised by P is a new issue that is not before the
Court.
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