Estate of Dora Halder, Deceased, Anita Halder MacDougall, Executrix - Page 2




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          Background                                                                  
               Dora Halder (decedent) died on April 21, 1997, in New York,            
          New York.  Decedent’s daughter, Anita Halder MacDougall, resided            
          in Oyster Bay, New York, when the petition was filed in this                
          case.                                                                       
               The petition disputed, among other adjustments, respondent’s           
          determination in the notice of deficiency that the fair market              
          value of decedent’s interest in the limited partnership was                 
          $1,627,960 on the date of death.  On October 17, 2001, the Court            
          set the trial date for March 18, 2002.                                      
               On December 14, 2001, the parties met with Appeals Officer             
          Howard H. Lindenbaum (Mr. Lindenbaum) to discuss the case.  Mr.             
          Lindenbaum, respondent’s counsel Monica E. Koch (Ms. Koch), the             
          estate’s counsel Robert D. Whoriskey (Mr. Whoriskey) and co-                
          counsel Charles R. Goulding (Mr. Goulding), and the estate’s                
          accountant Gordon S. Sherland (Mr. Sherland) were present at this           
          meeting.  The parties discussed the value of the limited                    
          partnership.  The estate’s representatives indicated that they              
          would make an offer of settlement following this meeting.                   
               On January 10, 2002, Mr. Sherland sent Mr. Lindenbaum a                
          settlement proposal in which Mr. Sherland proposed that, as a               
          starting point for the calculation, the limited partnership be              
          valued at $869,000 in 1987, when the estate claims the limited              
          partnership was formed.                                                     






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