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ESTATE OF FLANDREAU v. C.I.R.

No. 1254, Docket 92-4182.

994 F.2d 91 (1993)

ESTATE OF Lulu K. FLANDREAU, Deceased, Richard Knies, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided May 26, 1993.

Attorney(s) appearing for the Case

John O'Shea, Manhasset, NY, for petitioner-appellant.

David A. Shuster, Washington, DC (James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Jonathan S. Cohen, Attys., Tax Div., Dept. of Justice, Washington, DC, on the brief), for respondent-appellee.

Before ALTIMARI, LUMBARD, and LOKEN, Circuit Judges.

LOKEN, Circuit Judge:

The Estate of Lulu K. Flandreau appeals a decision of the United States Tax Court, Clapp, J., denying the Estate an estate tax deduction under I.R.C. § 2053 for the unpaid balance of promissory notes executed by decedent payable to her sons and daughters-in-law. Estate of Flandreau v. Commissioner, T.C. Memo. 1992-173, 63 T.C.M. (CCH) ¶ 2512 (1992). We affirm.

I.

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