Estate of Helis v. Commissioner

OPINION.

ARundell, Judge:

Section 812 (b) (2) of the Internal Revenue Code of 1939 provides that for the purpose of the estate tax the value of the net estate shall be determined “by deducting from the value of the gross estate * * * such amounts * * * for administration expenses * * * as are allowed by the laws of the jurisdiction * * * under which the estate is being administered * * Section 81.32 of Treasury Regulations 105, relating to the estate tax under the 1939 Code, provides that “Administration expenses include (1) executor’s commissions; (2) attorney’s fees; and (3) miscellaneous…