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ESTATE OF SMITH v. COMMISSIONER

Docket No. 4251-69.

57 T.C. 650 (1972)

ESTATE OF DAVID SMITH, DECEASED, IRA M. LOWE, CLEMENT GREENBERG, ROBERT MOTHERWELL, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 23, 1972.

Attorney(s) appearing for the Case

Ira M. Lowe, for the petitioner.

St. Clair Reeves, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $2,444,629.17 in the Federal estate tax of the Estate of David Smith (hereinafter referred to as Smith or decedent).

Several issues raised in the petition have been either resolved by agreement of the parties or abandoned by petitioner. The following issues remain for decision: (1) The fair market value of 425 sculptures created by Smith and in his possession...

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