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the opinion of the Chief Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: These matters are
before the Court on Lee Nelson Shaw’s (Mr. Shaw) and Virginia
Marie Sweeney’s (Mrs. Sweeney) separate applications to
perpetuate testimony, filed pursuant to Rule 82. (For
convenience, we will refer to Mr. Shaw and Mrs. Sweeney,
collectively, as the applicants.) The applicants do not have
current petitions for redetermination of deficiencies before the
Court.
Background
The applicants are siblings. Mr. Shaw and Mrs. Sweeney were
71 and 78 years of age, respectively, at the time the
applications herein were made. At the time of filing the
applications, Mr. Shaw resided at Vero Beach, Florida, and Mrs.
Sweeney resided at Chappaqua, New York.
The applications in these cases state that, in 1951, the
applicants, along with their brother, Robert S. Shaw (now
deceased), each formed separate trusts. The trusts named City
Bank Farmers Trust Co. (now Citibank) and Marie A. Shaw, the
applicants’ mother, as trustees. The applications further state:
1(...continued)
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011