Round numbers going into trial the disputed assets were valued at $5 million by the Estate and $482 million by the IRS.  Judge Holmes at $111 million leaned toward the Estate, but it was not a real blowout.  The top estate tax rate in 2009 was 45% so the final check the Estate writes will probably still be, as we say, a number.  The notice of deficiency that prompted the petition that got the litigation rolling had much more dramatic adjustments.  They totaled over $1.1 billion with image and likeness adjusted upward by $434 million, NHT II by $469 million and NHT III by $58 million.