Estate of Doris Z. Tenenbaum, Deceased Third National Bank in Nashville v. Commissioner of Internal Revenue

BOYCE F. MARTIN, Jr., Chief Judge.

This case is an appeal from a Tax Court decision upholding a federal estate tax assessment by the Commissioner of Internal Revenue against the Estate of Doris Z. Tenenbaum. Estate of Tenenbaum v. C.I.R., T.C. Memo.1995-48, 1995 WL 35338. The Tax Court held that Tennessee law requires the estate to reduce the amount of the elective share it reported for purposes of the marital deduction in order to reflect the extent to which the elective share was burdened by decedent’s secured debt. Third National Bank in Nashville, Executor of the estate, appeals the Tax…