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ESTATE OF JENNER v. C. I. R.

No. 77-2135.

577 F.2d 1100 (1978)

ESTATE of Helen Baker JENNER, Deceased and Continental Illinois National Bank and Trust Company of Chicago, Executor, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 16, 1978.

Attorney(s) appearing for the Case

Don S. Harnack, Chicago, Ill., for petitioners-appellants.

Carleton D. Powell, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before FAIRCHILD and BAUER, Circuit Judges, and JAMESON, Senior District Judge.

JAMESON, Senior District Judge.

The executor of the estate of Helen Baker Jenner, deceased, appeals from a decision of the Tax Court holding that the commission the estate paid to the underwriters for the public sale of a large block of stock through a registered secondary offering was not a deductible administrative expense under section 2053(a)(2) of the Internal Revenue Code of 1954.1 36 T.C.M. (CCH) 241

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