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ESTATE OF KOLCZYNSKI v. COMMISSIONER

Docket No. 022096-03.

90 T.C.M. 290 (2005)

T.C. Memo. 2005-217

Estate of Nora Kolczynski, Deceased, Matthew Hoffmeier, Executor v. Commissioner.

United States Tax Court.

September 20, 2005.

Attorney(s) appearing for the Case

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 held at her death.1 The parties disagree as to the highest and best use of DP on the valuation date and the method to value DP. We hold that...

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