Legal Opinion

Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann Kokernot Lacy v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided May 27, 1997No. 96-60057PublishedCited by 8 opinions

1Opinion of the Court

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 December 7, 1990. Her daughter was named executrix of her estate. At the time of her death, Decedent partly owned a 103,843.21 acre cattle ranch in West…

2Cases cited7 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
  3. Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
  4. Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
  5. J. & O. Altschul Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1930

2 more not listed; retrieve them via the Exa API.

3Cited by8 opinions

  1. Frank W. Smith Janice M. Smith v. United StatesCourt of Appeals for the Fifth Circuit · 2003
  2. Thomas E. Johnston, and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
  3. Buesing v. United StatesUnited States Court of Federal Claims · 1999
  4. Buesing v. United StatesUnited States Court of Federal Claims · 2000
  5. Gonzales v. Columbia Hospital at Medical City Dallas Subsidiary, L.P.District Court, N.D. Texas · 2002

3 more not listed; retrieve them via the Exa API.

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