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ESTATE OF COHEN v. COMMISSIONER

Docket No. 1276-67.

29 T.C.M. 1221 (1970)

T.C. Memo. 1970-272

Estate of Frank Cohen, Deceased, Lillian Cohen and Milton Horowitz, Executors, and Lillian Cohen v. Commissioner.

United States Tax Court.

Filed September 24, 1970.

Attorney(s) appearing for the Case

Arthur H. Sobel, 25 Broadway, New York, N. Y., for the petitioners. Agatha L. Vorsanger and Harvey R. Poe, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined a deficiency in Frank and Lillian Cohen's income tax for the year 1960 in the amount of $50,471.

Concession having been made, the only issues remaining for us to decide are: (1) whether prepaid interest on a loan, the proceeds of which were used to purchase U. S. Treasury notes, is deductible; (2) are expenses paid in advance in...

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