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the School of Art at the University of California at Los
Angeles.1 Dean Stussy resided in the residence until his death.
The Foundation is a section 501(c)(3) organization that was
formed in 1990. The Foundation is responsible for storing,
cataloging, and selling the paintings and other artwork of Dean
Stussy (collectively, Dean Stussy artwork). The Foundation began
storing the Dean Stussy artwork at the residence at or about the
time the Foundation was formed and continued to store the Dean
Stussy artwork there throughout the subject year. The Dean
Stussy artwork stored at the residence included approximately 100
pieces which measured 4 feet by 8 feet and approximately 1,000
pieces which measured 4 feet by 4 feet. The Foundation valued
its Dean Stussy artwork at $820,934 as of December 31, 1998.
Pursuant to a “Deed of Gift and License” dated April 30,
1990, Dean Stussy made two gifts to the Foundation. The first
gift was the Dean Stussy artwork. The second gift was a license
to the exclusive use of four rooms (collectively, rooms) in the
residence. The rooms, none of which during the subject year were
used by petitioner for personal purposes, totaled 900 square
feet. Petitioner was not entitled to collect from the Foundation
any rent on the rooms, and the Foundation was liable for only the
payment of insurance.
1 Dean Stussy painted more than 7,000 paintings.
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Last modified: May 25, 2011