- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011