Estate of Gertrude H. Saunders, William W. Saunders, Jr., and Richard B. Riegels, Co-Executors v. Commissioner

OPINION

Cohen, Judge:

Respondent determined a deficiency of $14,400,000 in estate tax due from the Estate of Gertrude H. Saunders (decedent). Respondent also determined a penalty under section 6662(h) of $5,760,000, but that penalty has now been conceded. The case is before the Court for a preliminary determination of whether a claim against the estate satisfies the requirements of section 20.2053-l(b)(3), Estate Tax Regs., as in effect for the date of the decedent’s death that a claim may be deducted “though its exact amount is not then known, provided it is ascertainable with reasonable…