Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann K. Lacy, Executrix - Page 4

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          section 2032A, and she never mentioned that she might want to               
          consider the application of that section once the parties finally           
          agreed to the fair market value of the Ranch.  On June 19, 1995,            
          when the case was called for trial, counsel for respondent                  
          announced that the parties had reached a basis for settlement on            
          all issues raised in the notice of deficiency.  Subsequently, on            
          July 3, 1995, the parties filed a three-page stipulation of                 
          settled issues.  The agreement contains no reference to section             
          2032A or to Executrix's protective election under that section.             
          In relevant part the stipulation of settlement states:                      
               3.   The parties stipulate to the following terms of                   
                    a.   With respect to the increase in the value of                 
               real estate included in the gross estate, the issues                   
               were resolved as follows:                                              
                         I.   The parties agree to the value of the                   
                         entire 103,843 acres of the cattle ranch at                  
                         $80.00 per acre.                                             
                         ii. In addition, the parties agree that                      
                         petitioner is entitled to a discount of 20%                  
                         on the entire 103,843 acres to reflect the                   
                         deceased's partial interest in the property.                 
                         iii. In addition, petitioner concedes that                   
                         the gifts made on January 24, 1990 under the                 
                         authority of the power of attorney should be                 
                         included in the gross estate for tax                         
                    b.   With respect to the $18,867.00 increase in                   
               miscellaneous property due to the inclusion of ranch                   
               lease income, the petitioner concedes the issue in                     
               full, as reflected in petitioner's amended return filed                

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