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ESTATE OF O'KEEFEE v. COMMISSIONER

Docket No. 18344-90.

63 T.C.M. 2699 (1992)

T.C. Memo. 1992-210

Estate of Georgia T. O'Keeffe, Deceased, Raymond R. Krueger, Personal Representative, Juan Hamilton, Personal Representative, and June O'Keeffe Sebring, Personal Representative v. Commissioner.

United States Tax Court.

Filed April 8, 1992.

Attorney(s) appearing for the Case

Joseph E. Earnest, R. Donald Turlington, Robert P. Worcester, Eileen Caulfield Schwab, E. Michael Bradley, and Judith Welcom, for the petitioner. Deborah A. Butler, George E. Gasper, and James E. Archie, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined a deficiency of $6,014,493 in the estate tax of the estate of Georgia T. O'Keeffe, deceased (O'Keeffe). After concessions, the issue for decision is the fair market value after application of the appropriate blockage discount of O'Keeffe's works left in her estate at the date of death. Unless otherwise indicated, all section references...

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