Ungerman Revocable Trust v. Commissioner
United States Tax Court
Petitioner incurred and paid interest on the unpaid balance of a Federal estate tax liability deferred under sec. 6166, I.R.C. 1954. Held, the interest is deductible as an administration expense under sec. 212, I.R.C. 1954. Consequently, even though the interest is also deductible under sec. 163, I.R.C. 1954, petitioner's claimed deduction for the interest qualifies as a deduction for a cost "paid or incurred in connection with the administration of * * * [an] estate or…
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Petitioner incurred and paid interest on the unpaid balance of a Federal estate tax liability deferred under sec. 6166, I.R.C. 1954. Held, the interest is deductible as an administration expense under sec. 212, I.R.C. 1954. Consequently, even though the interest is also deductible under sec. 163, I.R.C. 1954, petitioner's claimed deduction for the interest qualifies as a deduction for a cost "paid or incurred in connection with the administration of * * * [an] estate or trust" within the meaning of sec. 57(b)(2)(B)(i), I.R.C. 1954. Petitioner is therefore not subject to the alternative…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:*
By notice of deficiency dated January 10, 1986, respondent determined a deficiency in petitioner’s Federal income tax for the fiscal year ended May 31, 1983, in the amount of $50,944. The only issue for decision in this case is whether a deduction claimed by petitioner for an interest expense, incurred and paid by petitioner on the unpaid balance of a Federal estate tax liability deferred under section 6166,1 qualifies as a deduction for a cost “paid or incurred in connection with the administration of * * * [an] estate or trust” within the meaning of section…
2Cases cited7 opinions
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- Huntington v. CommissionerUnited States Board of Tax Appeals · 1937
- Hewett v. CommissionerUnited States Tax Court · 1967
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