Lee Nelson Shaw - Page 2




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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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