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ESTATE OF DUVAL v. COMMISSIONER

Docket No. 4731.

4 T.C. 722 (1945)

ESTATE OF ETHEL M. DUVAL, DECEASED, BY THOMAS M. ROBINSON, JR., AND WESTON SHATTUCK ROBINSON, AS EXECUTORS OF HER LAST WILL AND TESTAMENT, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 2, 1945.

Attorney(s) appearing for the Case

M. W. Dobrzensky, Esq., and James H. Anglim, Esq., for the petitioners.

Arthur L. Murray, Esq., for the respondent.

The respondent determined a deficiency of $48,214.31 in estate tax against the estate of Ethel M. DuVal.

The single issue is whether the sum of $175,000 representing the balance due on notes of a corporation, payment of which was guaranteed by the decedent and another, may be deducted from gross estate as a debt of the decedent, where the maker of the notes was financially able to pay them.

FINDINGS OF FACT.

Ethel M. DuVal, hereinafter referred to...

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