T.C. Memo. 2004-123 UNITED STATES TAX COURT ESTATE OF MICHEL DUNIA, DECEASED, RENEE HAWLEY AND MICHEL DUNIA, JR., EXECUTORS AND TRUSTEES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6115-00. Filed May 20, 2004. 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 offersPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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