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Stanard T. Klinefelter, for petitioner.
Susan T. Mosley, for respondent.
MEMORANDUM OPINION
LARO, Judge: This matter is before the Court on the
parties' cross-motions for entry of decision in accordance with a
stipulation of settlement filed July 3, 1995. We must decide
whether the subject decision should reflect the application of
section 2032A.1 We hold that it should not.
We refer to Golda E. Rixon Kokernot as decedent. At the
time of her death decedent was a resident of the State of Texas.
We refer to Mary Ann Kokernot Lacy as Executrix. At the time
Executrix filed her petition with the Court she was also a
resident of the State of Texas.
Background
Decedent died on December 7, 1990. At the time of her death
decedent owned a large cattle ranch located in Brewster and Jeff
Davis Counties, Texas, called the "Kokernot 06 Ranch" (Ranch).
On September 7, 1991, Mary Ann K. Lacy as the Executrix for the
estate of Golda E. Rixon Kokernot, filed the estate's Federal
estate tax return, in which Executrix reported the fair market
1 Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the date of the decedent's
death, and Rule references are to the Tax Court Rules of Practice
and Procedure.
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