ESTATE OF KOSOW

No. 93-4307.

45 F.3d 1524 (1995)

ESTATE OF Joseph P. KOSOW, Deceased. Eleanor C. KOSOW, Personal Representative, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

February 28, 1995.


Attorney(s) appearing for the Case

Lester G. Fant, III, John Wester, Nina B. Finston, Carter G. Phillips, Sidley & Austin, Washington, DC, for appellant.

Gary R. Allen, Joy L. Pritts, Loretta C. Argrett, Asst. Atty. Gen., Ann B. Durney, Bridget M. Rowan, Dept. of Justice, Tax Div., Washington, DC, for appellee.

Before COX, Circuit Judge, FAY, Senior Circuit Judge, and CARNES, District Judge.


CARNES, District Judge:

The Estate of Joseph Kosow has appealed the Tax Court's decision to disallow a deduction for a claim that was made against and paid by the estate. In particular, the Tax Court held that the estate had failed to prove that the agreement by the deceased that gave rise to the claim was an agreement supported by full and adequate consideration, as required by law. We disagree and hold that the Tax Court...

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