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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
settlement:
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
purposes.
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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