Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann K. Lacy, Executrix - Page 2

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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.                                             
               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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