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 offers
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