Reports of the Tax Court of the United States, Volume 98

9th Cir additions to tax affd alternative minimum tax amended amount apply asserts bankruptcy Carlsbad property charitable claim collateral estoppel Commissioner Condor Congress contends contract cost decedent decedent's deduction deficiencies determined distribution election estate tax facts Federal income tax filed gift tax gross income Halliburton held Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction legislative history loan marital deduction Normac notice of deficiency notice of liability obligation opinion Oregon paid parties partnership payments percent petition petitioner Petitioner argues petitioner's prior provides purchase purposes pursuant QTIP qualified reasonable receipt received references regulations Rept res judicata respect Respondent determined respondent's Roseburg Rule settlement agreement Stat statute statutory summary judgment supra surviving spouse T.C. Memo Tax Court tax deficiencies tax liability taxable income taxable year ending taxpayer term timber tion trust United Universale USVI Willard Robertson