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ESTATE OF KOKERNOT v. COMMISSIONER

Docket No. 16088-94.

70 T.C.M. 1559 (1995)

T.C. Memo. 1995-590

Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann K. Lacy, Executrix v. Commissioner.

United States Tax Court.

Filed December 13, 1995.

Attorney(s) appearing for the Case

Stanard T. Klinefelter, Baltimore, Md., for the petitioner. Susan T. Mosley, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

This matter is before the Court on the parties' cross-motions for entry of decision in accordance with a stipulation of settlement filed July 3, 1995. We must decide whether the subject decision should reflect the application of section 2032A.1 We hold that it should not.

We refer to Golda E. Rixon Kokernot as decedent. At the time of her death decedent was a

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