ESTATE OF FLANDREAU v. COMMISSIONER

Docket No. 22448-89.

63 T.C.M. 2512 (1992)

T.C. Memo. 1992-173

Estate of Lulu K. Flandreau, Deceased, Richard Knies, Executor v. Commissioner.

United States Tax Court.

Filed March 24, 1992.


Attorney(s) appearing for the Case

John O'Shea, 305 Mill Spring Rd., Manhasset, N.Y., for the petitioner. William J. Gregg, for the respondent.


Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in estate tax in the amount of $38,756.35. After concessions by the parties, the issue for consideration is whether petitioner is entitled to claim deductions for notes in the amount of $102,000 executed by decedent in favor of her children. We hold that petitioner is not entitled to such deductions.

All section references are to the Internal Revenue Code in effect at the date of...

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