Estate of James A. Elkins, Jr., Margaret Elise Joseph and Leslie Keith Sasser, Independent Executors v. Commissioner

Halpern, Judge:

By notice of deficiency issued to petitioners (notice), respondent determined an estate tax deficiency of $9,068,265. Petitioners (Ms. Sasser and Ms. Joseph) are the coexecutors of the Estate of James A. Elkins, Jr. (estate), and are decedent’s daughters. Their brother, James A. Elkins III (James III), who was also a coexecutor of the estate, died on June 10, 2010, less than a month after respondent issued the notice, and will not be replaced as a coexecutor. The issue to be decided is the total fair market value of decedent’s undivided fractional interests in 64 works of art,…