ESTATE OF RATLIFF v. COMMISSIONER

Docket No. 16017-91.

101 T.C. 276 (1993)

ESTATE OF HARRY W. RATLIFF, DECEASED, THE FIRST NATIONAL BANK AND TRUST COMPANY, VINITA, OKLAHOMA, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 30, 1993.


Attorney(s) appearing for the Case

Thomas J. McGeady and John J. McQueen, for petitioner.

Edith F. Moates, for respondent.


OPINION

TANNENWALD, Judge:

This case is before us on petitioner's motion for summary judgment. The issue is whether respondent is entitled, under section 446,1 to allocate certain payments, designated to be applied to principal by agreement between the debtor and petitioner's decedent as creditor, to interest income during each of the taxable years of the decedent ending December 31, 1986, through December 31, 1988. If...

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