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.Page: 1 2 3 4 5 6 7 8 9 10 Next
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