Estate of Golda E. Rixon Kokernot, Deceased, Mary Ann Kokernot Lacy v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
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
- Welch v. HelveringSupreme Court of the United States · 1933
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- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- J. & O. Altschul Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1930
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