Robert Rauschenberg, “one of the most prominent and prolific artists of the twentieth century,”1 died in 2008, leaving an estate valued at $605,645,595 for federal estate tax purposes. The bulk of the assets, including two closely held companies— Robert Rauschenberg, Inc. and Untitled Press, Inc., which operated the decedent’s art businesses—were held in the Robert Rauschenberg Revocable Trust, first created in 1994 and last amended and restated in 2008.  ...

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