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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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Last modified: May 25, 2011