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ESTATE OF KOSOW v. COMMISSIONER

Docket No. 11003-89.

64 T.C.M. 727 (1992)

T.C. Memo. 1992-539

Estate of Joseph P. Kosow, Deceased, Eleanor C. Kosow, Personal Representative v. Commissioner.

United States Tax Court.

Filed September 14, 1992.

Attorney(s) appearing for the Case

Lester G. Fant III, 1722 Eye St., N.W., Washington, D.C., for the petitioner. Sergio Garcia-Pages, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined a deficiency in the Federal estate tax of the Estate of Joseph P. Kosow, deceased, in the amount of $13,137,087 which reflected in part additional assets included in the estate by respondent. Respondent has conceded the entire deficiency except for the sum of $4 million which the estate claims is deductible as a debt of the estate under section 2053.1

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