Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 8

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          paragraph (i) of the explanation of adjustments.  In particular,            
          respondent admits that the second sentence should have read:  "On           
          October 17, 1990, James R. Rickman directed the First Union                 
          Brokerage Services of North Carolina to transfer two U.S.                   
          Treasury Notes totalling $300,000 to Kaye Rickman, Janet Tipton             
          and James Tipton."  (Emphasis added.)                                       
          In response to the notice of deficiency, petitioner filed a                 
          timely petition for redetermination with this Court.  Shortly               
          after respondent filed her answer to the petition, the parties              
          became embroiled in both a discovery dispute and a disagreement             
          over whether either party should be granted leave to file an                
          amendment to their initial pleading.  A hearing was scheduled in            
          Washington, D.C., on June 28, 1995, for the purpose of resolving            
          five pending motions stemming from these particular disputes.  On           
          the eve of this hearing, petitioner filed both a Motion to                  
          Dismiss for Lack of Jurisdiction and a Motion for Summary                   
          Judgment.4                                                                  
          In the meantime, by letter dated June 22, 1995, Doris K.                    
          Rickman wrote to the Internal Revenue Service District Director             
          in Greensboro, North Carolina, and requested a written statement            
          pursuant to section 7517 explaining the property valuations                 


          4  Although the June 28, 1995, hearing was conducted as                     
          scheduled, the Court decided to reserve ruling on the various               
          collateral matters in dispute in favor of first ruling on the               
          jurisdictional issue raised in petitioner's motion to dismiss.              




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