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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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Last modified: May 25, 2011