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ESTATE OF BOYCE v. COMMISSIONER

Docket No. 367-70.

31 T.C.M. 1017 (1972)

T.C. Memo. 1972-204

Estate of Marguerite K. Boyce, Victor R. Wolder and Manufacturers Hanover Trust Company, Executors v. Commissioner.

United States Tax Court.

Filed September 21, 1972.

Attorney(s) appearing for the Case

Hewitt A. Conway, 350 Park Ave., New York, N.Y., Richard J. Concannon, and John F. Rossi, for the petitioners. Michael A. Menillo, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $32,137.86 in the estate tax of the estate of Marguerite K. Boyce. Certain concessions having been made, the sole question remaining for decision is whether cash and securities paid to decedent's attorney under a provision in the decedent's will can be deducted from her gross estate under section 2053(a)1 as payment of a claim for...

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