Estate of Jacqueline A. Stotz, Deceased, Trent McGee and Leo Kaplan, Co-Executors and Jackie Stotz Trust, Trent McGee and Leo Kaplan, Co-Trustees - Page 1

                                 T.C. Memo. 1998-450                                  

                               UNITED STATES TAX COURT                                

                ESTATE OF JACQUELINE A. STOTZ, DECEASED, TRENT MCGEE                  
                AND LEO KAPLAN, CO-EXECUTORS AND JACKIE STOTZ TRUST,                  
               TRENT MCGEE AND LEO KAPLAN, CO-TRUSTEES, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18732-96.             Filed December 23, 1998.              

               Elliott H. Kajan and Cameron Williams, for petitioners.                
               Louis B. Jack, for respondent.                                         

                                 MEMORANDUM OPINION                                   
               GERBER, Judge:  This case had been calendared for trial at             
          the Los Angeles, California, trial session beginning March 23,              
          1998.  Shortly before that session, the Court was advised by the            
          parties' representatives of a settlement, and, as a result, the             
          Court continued this case from the trial session.  After several            

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