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MEMORANDUM OPINION
LARO, Judge: Respondent moves for entry of decision, and
she has lodged a proposed decision with the Court. Executor
objects to respondent’s motion, and he moves to defer entry of
decision until the earlier of: (1) June 6, 2001, (2) payment of
Decedent’s Federal gift taxes, or (3) any other date agreed to by
the parties. Respondent objects to Executor’s motion.
As discussed herein, we will grant respondent’s motion and
enter her proposed decision. Unless otherwise stated, section
references are to the Internal Revenue Code in effect for the
relevant dates. Rule references are to the Tax Court Rules
of Practice and Procedure. Dollars, unless otherwise noted, are
rounded to the nearest dollar. The term “Decedent” refers to
Louise Nevelson. The term “Executor” refers to Mike Nevelson.
Background
Decedent was an artist until her death on April 17, 1988.
When she died, she resided in New York County, New York.
Decedent’s estate includes thousands of her works of art.
Executor resided in New Fairfield, Connecticut, when he
petitioned the Court on April 14, 1992, to redetermine
respondent’s determination of a $6,553,148 deficiency in
Decedent's estate's Federal estate tax and a $327,657 addition
thereto under section 6653(a).1 Respondent’s determination was
1 Respondent agrees with Executor that the deficiency and
addition to tax will be $5,453,185 and $272,659, respectively, if
(continued...)
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Last modified: May 25, 2011