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Estate of Dunia v. Commissioner

Docket. No. 6115-00.

87 T.C.M. 1353 (2004)

T.C. Memo. 2004-123

Estate of Michel Dunia, Deceased, Renee Hawley and Michel Dunia, Jr., Executors and Trustees v. Commissioner.

United States Tax Court.

May 20, 2004.

Attorney(s) appearing for the Case

Paul N. Frimmer and Martin Gelfand, for petitioner.

Jack Klinghoffer, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GOEKE, Judge:

Respondent determined a deficiency of $8,675,853 in the Federal estate tax of the estate of decedent Michel Dunia. After concessions, the issue for decision is the value of a tract of real property held for sale as a commercial site. Both parties presented experts who valued the property using comparable sales. Respondent also relies on alleged offers for the property, a partnership agreement, and a partial...

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