ularly ironical when viewed in the light of the Tax Court's correct distinction of this case from, among others. Estate of Scull v. Commissioner. 67 T.C.M. (CCH) 2953 (1994). and Stone v. United States. No. 06-0259. 2007 WI. 2318974. at •3 (N.D. Cal. Aug. 10. 2007). The courts in both of those cases aw