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ESTATE OF STURGIS v. COMMISSIONER

Docket No. 12219-85.

54 T.C.M. 221 (1987)

T.C. Memo. 1987-415

Estate of Ruby S. Sturgis, Deceased, First Commercial Bank Executor v. Commissioner.

United States Tax Court.

Filed August 24, 1987.

Attorney(s) appearing for the Case

Byron M. Eiseman, Jr., James E. Harris, and Louis H. Mathis, 2000 First Commercial Bldg., Little Rock, Ark., for the petitioner. Robert J. Shilliday, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in petitioner's estate tax in the amount of $4,106,548.23. The issues for decision are (1) whether respondent's expert1 correctly valued certain timberlands owned by Ruby S. Sturgis ("decedent") at her death and (2) whether petitioner may claim as a deduction from the gross estate certain interest expenses under section 2053.

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