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ESTATE OF NORRIS v. COMMISSIONER

Docket No. 1852-78.

42 T.C.M. 408 (1981)

T.C. Memo. 1981-368

Estate of Dellora A. Norris, Continental Illinois National Bank and Trust Company of Chicago, George N. Gaynor and Robert C. Norris, Co-executors v. Commissioner.

United States Tax Court.

Filed July 16, 1981.

Attorney(s) appearing for the Case

John K. O'Connor and Leland E. Hutchinson, 115 S. LaSalle St., Chicago, Ill., for the petitioners. Tom Quinn, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined deficiencies of $48,918.26 and $72,756.53 in decedent's1 Federal income taxes for 1973 and 1974, respectively. After concessions, the issues remaining for decision are:

(1) Whether decedent incurred or continued indebtedness in order to purchase or carry tax-exempt obligations within the meaning of section 265(2).2

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