FINDINGS OF FACT AND CONCLUSIONS OF LAW
WISE, Chief Judge.
Plaintiffs seek a refund of estate taxes and interest paid by them as co-executors of their father's estate. In dispute is one item, disallowed as a deduction from the gross estate by the Internal Revenue Service, consisting of a loan from the decedent's wife to the decedent. Plaintiffs assert that the deduction was valid, under 26 U.S.C. § 2053(c)(1)(A), as a debt "bona fide and for an adequate...
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