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ESTATE OF KOKERNOT

No. 96-60057.

112 F.3d 1290 (1997)

ESTATE OF Golda E. Rixon KOKERNOT, Deceased, Mary Ann Kokernot LACY, Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

May 27, 1997.

Attorney(s) appearing for the Case

Stanard T. Klinefelter, Brett Ingerman, Stuart A. Smith, Piper & Marbury, Baltimore, MD, for Petitioner-Appellant.

Gary R. Allen, Ann Belanger Durney, Anthony T. Sheehan, Loretta Argrett, Asst. Atty. General, U.S. Department of Justice, Tax Division, Appellate Section, Washington DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, for C.I.R.

Before REYNALDO G. GARZA, EMILIO M. GARZA and DeMOSS, Circuit Judges.

REYNALDO G. GARZA, Circuit Judge:

A decedent's estate appeals a judgment of the United States Tax Court holding that it waived its ability to elect special-use valuation for certain qualified property under I.R.C. § 2032A because it failed to raise the topic in its petition for review or during the negotiations that led to the filing of a stipulation of settlement with the Tax Court. We affirm.

I.

Golda E. Rixon Kokernot ("Decedent") died on...

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