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ESTATE OF COURTNEY v. COMMISSIONER

Docket No. 3984-73.

62 T.C. 317 (1974)

ESTATE OF QUINTARD PETERS COURTNEY, DECEASED, QUINTARD P. COURTNEY, JR., AND WILL ALLEN COURTNEY, CO-INDEPENDENT EXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 18, 1974.

Attorney(s) appearing for the Case

Richard Lee Brown, for the petitioners.

Kemble White, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a Federal estate tax of $5,690.03 against the petitioners. The issues for decision are whether the Estate of Quintard Peters Courtney is entitled to a deduction for either a claim against the estate under section 2053(a)(3), I.R.C. 1954,1 or for a mortgage debt under section 2053(a)(4).

All of the facts have been stipulated and are found accordingly.

Petitioners...

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