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ESTATE OF KEETON v. COMMISSIONER

Docket No. 20067-03.

92 T.C.M. 478 (2006)

T.C. Memo. 2006-263

Estate of Ronald G. Keeton, Deceased, Kimberly Keeton Spence, Personal Representative, Petitioner v. Commissioner.

United States Tax Court.

December 13, 2006.

Attorney(s) appearing for the Case

Douglas A. Wright, for petitioner.

Lauren B. Epstein, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

Respondent issued a notice of deficiency in the Federal estate tax of the Estate of Ronald G. Keeton (the estate) of $46,690. After concessions,1 the sole issue for decision is whether the estate is entitled to the family-owned business deduction under section 2057.2 In response to an argument respondent made in his opening brief, the estate has

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