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SUPPLEMENTAL MEMORANDUM OPINION
MARVEL, Judge: Petitioner and respondent filed computations
for entry of decision under Rule 155.1 We must decide which
party’s method of computation is appropriate in determining the
amount of petitioner’s estate tax deficiency.
Background
On June 27, 2007, the Court filed its opinion, Estate of
Gore v. Commissioner, T.C. Memo. 2007-169, in this estate tax
case and the related gift tax case consolidated therewith, Estate
of Gore v. Commissioner, docket No. 467-02 (gift tax case), but
withheld entry of decision so that the parties could submit
computations under Rule 155.2 On September 5 and 7, 2007,
respectively, petitioner and respondent filed their computations
for entry of decision in this estate tax case. Because
petitioner’s and respondent’s computations conflicted, we
scheduled a hearing on the unagreed Rule 155 computations and
ordered the parties to file statements detailing the items of
disagreement and the reasons for the dispute.
On October 5, 2007, petitioner filed a detailed statement of
the items of disagreement. Petitioner contends that respondent’s
1 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure.
2 The parties entered into an agreement resolving the
computation of petitioner’s gift tax liability, and decision was
entered in the gift tax case on Dec. 14, 2007.
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