ESTATE OF WARREN v. COMMISSIONER

Docket No. 36285-87.

93 T.C. 694 (1989)

ESTATE OF DOROTHY J. WARREN, DECEASED, RIVER OAKS TRUST COMPANY AND R. CLAY UNDERWOOD, COADMINISTRATORS WITH WILL ANNEXED OF THE ESTATE OF DOROTHY J. WARREN, DECEASED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 14, 1989.


Attorney(s) appearing for the Case

S. Stacy Eastland, Robert M. Weylandt, and Walter E. Workman, for the petitioner.

Rebecca W. Wolfe, for the respondent.


SCOTT, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of Dorothy J. Warren in the amount of $34,340,734.68. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision whether all administration expenses incurred by the Estate of Dorothy J. Warren (petitioner or the estate) must be subtracted from residuary corpus, thereby reducing the estate's charitable annuity deduction...

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