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ESTATE OF TODD v. COMMISSIONER

Docket No. 3953-70.

57 T.C. 288 (1971)

ESTATE OF JAMES S. TODD, JR., DECEASED, JANE JARVIS TODD RITCHEY, FORMERLY JANE JARVIS TODD, AND JAMES S. TODD III, EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 29, 1971.

Attorney(s) appearing for the Case

Robert S. Newkirk and Michael M. Gibson, for the petitioners.

Harold L. Cook, for the respondent.

DAWSON. Judge:

Respondent determined a deficiency of $252,018.28 in the Federal estate tax of the Estate of James S. Todd, Jr. The primary question to be decided is whether the estate is entitled to a marital deduction (amounting to $513,309.64) under section 2056, I.R.C. of 1954.1 A second question is whether the estate incurred an interest expense which is deductible under section 2053(a)(2). Other questions involving additional...

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