IRS, Prince Estate Agree on Property Values in Tax Court Case

Estate of Prince R. Nelson, Deceased,
Comerica Bank & Trust, N.A., Executor,
Petitioners
v.
Commissioner of Internal Revenue
Respondent

06/28/21

Stipulation of Settled Issues

UNITED STATES TAX COURT

THE PARTIES, by their undersigned counsel, do hereby stipulate and agree as set forth below with respect to certain items at issue in this case, reported on the Decedent's Estate Tax Return and adjusted in the Notice of Deficiency issued to petitioners on June 1, 2020:

1. Schedule A, Item 1, which was identified on the Estate Tax Return as 20.78 acres of undeveloped real property located in Chanhassen, Minnesota, had a fair market value of $1,735,523.39 as of April 21, 2016.

2. Schedule A, Item 2, which was identified on the Estate Tax Return as 149 acres of undeveloped real property located in Chanhassen, Minnesota, had a fair market value of $12,444,320.71 as of April 21, 2016.

3. Schedule A, Item 3, which was identified on the Estate Tax Return as 8.95 acres of undeveloped real property located in Chanhassen, Minnesota, had a fair market value of $747,494.43 as of April 21, 2016.

4. Schedule A, Item 4, which was identified on the Estate Tax Return as 6.62 acres of undeveloped real property located in Chanhassen, Minnesota, had a fair market value of $552,895.32 as of April 21,2016.

5. Schedule A, Item 5, which was identified on the Estate Tax Return as an industrial building located at 8020 Park Place in Chanhassen, Minnesota, had a fair market value of $840,000.00 as of April 21, 2016.

6. Schedule A, Item 7, which was identified on the Estate Tax Return as a 1.5-acre vacant residential lot located at 9401 Kiowa Trail in Chanhassen, Minnesota, had a fair market value of $670,000.00 as of April 21,2016.

7. Schedule A, Item 8, which was identified on the Estate Tax Return as a 1.82-acre vacant residential lot located at 9411 Kowa Trail in Chanhassen, Minnesota, had a fair market value of $230,000.00 as of April 21,2016.

8. Schedule A, Item 9, which was identified on the Estate Tax Return as a residential property located at 115 King Creek Road in Golden Valley, Minnesota, had a fair market value of $370,000.00 as of April 21, 2016.

9. Schedule A, Item 10, which was identified on the Estate Tax Return as a residential property located at 539 Newton Avenue North in Minneapolis, Minnesota, had a fair market value of $85,000.00 as of April 21, 2016.

10. Paisley Park Enterprises, Inc.'s reported ownership interest in the real property at 6921 Galpin Boulevard, Chanhassen, Minnesota, which was included in the value reported as part of Schedule B, Item 1 of the Estate Tax Return, had a fair market value of $269,766.15 as of April 21,2016.

11. Paisley Park Enterprises, Inc.'s reported ownership interest in the real property located at 7801 Audubon Road in Chanhassen, Minnesota, which was included in the value reported as part of Schedule B, Item 1 of the Estate Tax Return, had a fair market value of $4,800,000.00 as of April 21,2016.

12. Paisley Park Enterprises, Inc.'s reported ownership interest in the real property located at 2169 Red Fox Circle in Chanhassen, Minnesota, which was included in the value reported as part of Schedule B, Item 1 of the Estate Tax Return, had a fair market value of $147,000.00 as of April 21,2016.

13. NPG Records, Inc.'s reported ownership interest in the real property located in Turks and Caicos, which was included as part of Schedule B, Item 2 of the Estate Tax Return, had a fair market value of $9,800,000.00 as of April 21, 2016.

14. NPG Music Publishing, LLC's reported ownership interest in the real property located at 3420 Snelling Avenue in Minneapolis, Minnesota, which was included in the value reported as part of Schedule F, Item 1 and Schedule B, Item 1 of the Estate Tax Return, had a fair market value of $115,000.00 as of April 21, 2016.

15. No person shall be subject to or liable for any penalties set forth in the Notice of Deficiency with respect to any of the agreed upon adjustments set forth in the preceding 14 paragraphs.

WILLIAM M. PAUL
Acting Chief Counsel
Internal Revenue Service

MARK W. GREINER
Fredrikson & Byron
Counsel for Petitioners
Tax Court Bar No. GM0688
200 South Sixth Street Suite 4000
Minneapolis, MN 55402
mgreiner@fredlaw.com
Telephone: (612) 492-7000

Date: June 23, 2021

RANDALL L. EAGER
Special Trial Attorney
(Small Business/Self-Employed)
Tax Court Bar No. ER0256
2345 Grand Blvd., Suite 301
Kansas City, MO 64108
randall.l.eager@irscounsel.treas.gov
Telephone: (816) 823-0909

Date: June 28, 2021