I ax and Accounting Center Page 1 of 11 Bloomberg Tax and Accounting BNA Center' Source: Daily Tax Report: News Archive > 2017 > February > 02/23/2017 > TaxCore® - Court Documents > U.S. Tax Court > Estate of Kollsman v. Commissioner Estate of Kollsman v. Commissioner U.S. Tax Court ESTATE OF EVA FRANZEN KOLLSMAN, DECEASED. JEFFREY HYLAND, EXECUTOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. 26077-09 February 22, 2017 T.C. Memo. 2017.40 Kim E. Baptiste and Michael E. Swath, for petitioner. Jane 1 Kim and Robert A. Baxer, for respondent. GALE, Judge. MEMORANDUM FINDINGS OF FACT AND OPINION Respondent determined a $781,488 deficiency In the Federal estate tax of the Estate of Eva Franzen Kollsman (estate). t The deficiency arises [ 1.2] principally from respondent's determination that the estate underreported the values of two paintings held by decedent at her death on August 31, 2005 (valuation date). After concessions, 2 the sole issue for decision is the fair market values of the paintings on the valuation date. The parties have each introduced expert reports and testimony to support their respective positions. Unless otherwise noted, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the date of decedent's death, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts have been rounded to the nearest dollar. 2 A portion of the deficiency is attributable to respondent's determination that the estate failed to report taxable gifts made by decedent Eva Franzen Kollsman for taxable years 2002, 2003, and 2004. The estate has conceded this adjustment. FINDINGS OF FACT Some of the facts have been stipulated and, together with the exhibits attached thereto, are incorporated herein by this reference. L Background Eva Franzen Kollsman (decedent), a resident of New York, died testate on August 31, 2005. Her estate was administered in New Y