-3-
closely held stock which was the subject of respondent's
deficiency notices. Shortly before trial, respondent accepted
the valuation contained in the expert witness report. A
stipulation of settled issues and a revised stipulation of
settled issues were filed with the Court in May and August of
1994, respectively.3
Concurrently with the filing of the stipulation of settled
issues, petitioner filed her motion for litigation and
administrative costs. Respondent filed a response to
petitioner's motion, and petitioner filed a reply to respondent's
response to petitioner's motion. Also, since the filing of the
motion and responses, the parties have stipulated additional
facts and petitioner has filed an additional affidavit4.
Neither party initially requested a hearing in this matter.
Respondent eventually requested a hearing on the element of
petitioner's payment of legal fees, but the Court concludes that
a hearing is not necessary for the proper consideration and
disposition of this motion. Rule 232(a).
3The parties have agreed that there is a deficiency in gift
tax due from petitioner for the taxable year 1988 in the amount
of $24,942 and that there is no addition to tax due from
petitioner for the taxable year 1988 under the provisions of sec.
6660.
4Petitioner supplied an additional affidavit attesting to
the attorney's fees that she allegedly paid or incurred.
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