Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann K. Lacy, Executrix - Page 1

                                 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                      

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

Last modified: May 25, 2011