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Unless otherwise indicated, all section references are to
the Internal Revenue Code as of December 31, 1989, the date of
decedent's death.
After settlement of some issues, the only issue for decision
is the proper date-of-death value of decedent's ownership unit in
a partnership that owned real property in New York City.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner's legal
residence was in New York, New York.
The 225 Fourth Co. Partnership
In 1954, a group of investors including decedent organized a
general partnership under the laws of the State of New York by
the name of The 225 Fourth Co. Partnership (the FC Partnership)
for the purpose of purchasing two commercial office buildings and
land located at 225 and 233 Park Avenue South, Manhattan,
New York (the Partnership Properties).
The Partnership Properties occupy the entire block on the
east side of Park Avenue South between East 18th Street and East
19th Street. The Partnership Properties are located in a
neighborhood of Manhattan referred to as Midtown South.
Generally, office space that is located in Midtown South and that
is available for lease is regarded as secondary, as opposed to
primary, office space.
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