TITLE XV

DECISION

Rule 155.  Computation by Parties For Entry of
Decision
    (a) Agreed computations. Where the Court has filed or stated
its opinion determining the issues in a case, it may withhold
entry of its decision for the purpose of permitting the parties
to submit computations pursuant to the Court's determination of
the issues, showing the correct amount of the deficiency,
liability, or overpayment to be entered as the decision. If the
parties are in agreement as to the amount of the deficiency or
overpayment to be entered as the decision pursuant to the
findings and conclusions of the Court, then they, or either of
them, shall file promptly with the Court an original and two
copies of a computation showing the amount of the deficiency,
liability, or overpayment and that there is no disagreement that
the figures shown are in accordance with the findings and
conclusions of the Court. In the case of an overpayment, the
computation shall also include the amount and date of each
payment made by the petitioner. The Court will then enter its
decision.
   (b) Procedure in absence of agreement. If, however, the
parties are not in agreement as to the amount of the deficiency,
liability, or overpayment to be entered as the decision in
accordance with the findings and conclusions of the Court, then
either of them may file with the Court a computation of the
deficiency, liability, or overpayment believed by such party to
be in accordance with the Court's findings and conclusions. In
the case of an overpayment, the computation shall also include
the amount and date of each payment made by the petitioner. The
Clerk will serve upon the opposite party a notice of such filing
accompanied by a copy of such computation. If the opposite party
fails to file objection, accompanied or preceded by an
alternative computation, then, on or before a date specified in
the Clerk's notice, the Court may enter decision in accordance
with the computation already submitted. If in accordance with
this Rule computations are submitted by the parties which differ
as to the amount to be entered as the decision of the Court, then
the parties may, at the Court's discretion, be afforded an
opportunity to be heard in argument thereon and the Court will
determine the correct deficiency, liability, or overpayment and
will enter its decision accordingly.
   (c) Limit on argument. Any argument under this Rule will be
confined strictly to consideration of the correct computation of
the deficiency, liability, or overpayment resulting from the
findings and conclusions made by the Court, and no argument will
be heard upon or consideration given to the issues or matters
disposed of by the Court's findings and conclusions or to any new
issues. This Rule is not to be regarded as affording an
opportunity for retrial or reconsideration.

Rule 156.  Estate Tax Deduction Developing at or After
Trial
    If the parties in an estate tax case are unable to agree
under Rule 155, or under a remand, upon a deduction involving
expenses incurred at or after the trial, then any party may move
to reopen the case for further trial on that issue.

Rule 157.  Motion to Retain File in Estate Tax Case
Involving Section 6166 Election
    In any estate tax case in which the time for payment of an
amount of tax imposed by Code Section 2001 has been extended
under Code Section 6166, the petitioner shall, after the decision
is entered but before it becomes final, move the Court to retain
the Court's official case file pending the commencement of any
supplemental proceeding under Rule 262.
OTHER PROVISIONS:
   Note. New Rule 157 is effective with respect to cases for
which the Court's decision has not yet become final before July

Rule 158--159.  [Reserved]

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