Legal Opinion

Estate of Wheless v. Commissioner

United States Tax Court

Decided June 11, 1979No. Docket No. 10100-75Published

Post-death interest accrued on debts incurred by decedent not renewed by the executors is deductible as administration expense under sec. 2053(a)(2), I.R.C. 1954. Executors were unable to liquidate debts without selling illiquid assets of the estate at sacrifice prices.

1Opinion of the Court

Estate of William M. Wheless, Sr., Deceased, W. M. Wheless, Jr., W. M. Powell, Jr., Co-Independent Executors, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Wheless v. Commissioner

Docket No. 10100-75

United States Tax Court

72 T.C. 470; 1979 U.S. Tax Ct. LEXIS 105;

June 11, 1979, Filed

Decision will be entered under Rule 155.

Post-death interest accrued on debts incurred by decedent not renewed by the executors is deductible as administration expense under sec. 2053(a)(2), I.R.C. 1954. Executors were unable to liquidate debts without selling illiquid assets of the estate at…

2Cases cited7 opinions

  1. Estate of Bahr v. CommissionerUnited States Tax Court · 1977
  2. Todd v. CommissionerUnited States Tax Court · 1971
  3. Huntington v. CommissionerUnited States Board of Tax Appeals · 1937
  4. T. S. Ballance, Administrator De Bonis Non With the Will Annexed of the Estate of Samuel D. Jarvis, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1965
  5. Estate of Webster v. CommissionerUnited States Tax Court · 1976

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