Estate of Wheless v. Commissioner
United States Tax Court
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
OPINION
Drennen, Judge:
Respondent determined a deficiency of $54,816.02 in petitioner’s estate tax. The only issue presented in this case is whether interest paid by the executors which had accrued subsequent to the date of death on those debts contracted by the decedent which were not due and owing on or before the date of death constitute deductible administration expenses within the meaning of section 2053(a)(2), I.R.C. 1954,1 or are claims against his estate within the meaning of section 2053(a)(3), nondeductiblé through application of section 20.2053-4, Estate Tax Regs.
This case is…
2Cases cited6 opinions
- Estate of Bahr v. CommissionerUnited States Tax Court · 1977
- Todd v. CommissionerUnited States Tax Court · 1971
- Huntington v. CommissionerUnited States Board of Tax Appeals · 1937
- 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
- Estate of Webster v. CommissionerUnited States Tax Court · 1976
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Estate of Harrison v. CommissionerUnited States Tax Court · 1987
- Cleveland Bank & Trust Co. v. OlsenTennessee Supreme Court · 1984
- Estate of Wheless v. CommissionerUnited States Tax Court · 1979