T.C. Memo. 2005-217
UNITED STATES TAX COURT
ESTATE OF NORA KOLCZYNSKI, DECEASED, MATTHEW HOFFMEIER, EXECUTOR,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22096-03. Filed September 20, 2005.
John T. Catterson and Susan A. Teschner, for petitioner.
Monica E. Koch, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge: Respondent determined a Federal estate tax
deficiency of $843,146 against the Estate of Nora Kolczynski (the
estate). After concessions, the issue for decision is the value
of a tract known as Dawn Plantation (DP) which Nora Kolczynski
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