Yetta C. Levin, Independent of the Estate of Sarah Caplan v. Commissioner of Internal Revenue

JONES, Senior Judge.

The Tax Court of the United States, in a decision dated July 23, 1964, held there was a $41,753.08 deficiency in the estate tax filed by petitioner, Yetta C. Levin, for the estate of her deceased mother, Sarah Caplan. In so doing the Tax Court upheld a determination of the Commissioner of Internal Revenue that an alleged debt owed by the estate to the testamentary trust of Dave Cap-lan, the husband of Sarah, was legally unenforceable and so nondeductible on the estate tax return. The alleged debt was valued at $125,584.90. Petitioner seeks reversal of the decision of the…