Estate of William F. Luton, Deceased, Nancy L. Jackson, Robert S. Herdman, and William F. Luton, Jr., Co-Executors - Page 2

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          estate for Federal estate tax purposes.  Furthermore, we held               
          that petitioner was not liable for an addition to tax for                   
          undervaluation pursuant to section 6660.1  We directed the                  
          parties to submit computations pursuant to Rule 155.                        
               On October 20, 1995, respondent filed her Rule 155                     
          computations for entry of decision.  On November 20, 1995,                  
          petitioner filed its Rule 155 Computation.  Both parties filed              
          memoranda in support of their Rule 155 computations and in                  
          support of their objections to the other party’s Rule 155                   
          computations.  Petitioner also filed a response to respondent’s             
          memorandum.  Hereinafter, the parties’ Rule 155 computations and            
          memoranda in support thereof will be referred to as petitioner’s            
          or respondent’s Rule 155 computation, as the context requires.              
               Prior to the trial of this case, the parties filed a                   
          stipulation of partial agreement (SPA) containing nine numbered             
          paragraphs.  The SPA reflected the parties’ agreement as to a               
          number of issues relating to adjustments to the gross estate,               
          estate deductions, and adjusted taxable gifts to be incorporated            
          in the computation of petitioner’s estate tax deficiency, if any,           
          for entry of decision by the Court.                                         
               In the notice of deficiency, inter alia, respondent                    
          determined an adjustment to the value of the decedent’s stock               

               1    All section references are to the Internal Revenue Code           
          in effect as of the date of decedent’s death, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure,            
          unless otherwise indicated.                                                 




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