Estate of Kimberly A. Hicks, Deceased, Key Trust Company of Ohio, N.A., Administrator - Page 1

                                 T.C. Memo. 2007-182                                  

                               UNITED STATES TAX COURT                                

                  ESTATE OF KIMBERLY A. HICKS, Deceased, KEY TRUST                    
                 COMPANY OF OHIO, N.A., Administrator, Petitioner v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13779-02.              Filed July 10, 2007.                 

               Timothy G. Crowley, for petitioner.                                    
               Robert D. Kaiser, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               HOLMES, Judge:  Kimberly Hicks, while still a toddler, was             
          severely disabled in a collision at a railroad crossing.                    
          Litigation followed, and the largest part of the ultimate                   
          settlement was a lump sum to be allocated between Kimberly and              
          her father.  The Ohio court that allocated that lump sum gave               

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Last modified: November 10, 2007