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ESTATE OF GRAEGIN v. COMMISSIONER

Docket No. 37230-84.

56 T.C.M. 387 (1988)

T.C. Memo. 1988-477

Estate of Cecil Graegin, Deceased, Mercantile National Bank and Paul K. Graegin, Co-executors v. Commissioner.

United States Tax Court.

Filed September 28, 1988.

Attorney(s) appearing for the Case

Larry D. Blust and Paula Cozzi Goedert, One IBM Plaza, Chicago, Ill., for the petitioner. Joel D. Arnold and G. Roger Markley, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency in Federal estate tax against the Estate of Cecil Graegin, deceased (petitioner), in the amount of $696,325.42.

After concessions, the issues for decision are (1) whether a balloon payment of interest due upon maturity of an obligation, which was incurred in order to pay petitioner's Federal estate tax liability, is a deductible administration expense under...

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