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ESTATE OF VATTER v. COMMISSIONER

Docket No. 7228-72.

65 T.C. 633 (1975)

ESTATE OF JOSEPH VATTER, DECEASED, ANNA VATTER, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 31, 1975.

Attorney(s) appearing for the Case

Sydney R. Rubin, for the petitioner.

Bernard R. Baker III, for the respondent.

FORRESTER, Judge:

Respondent has determined a deficiency in estate tax in the amount of $517.40. Petitioner claims an overpayment based on reasonable attorneys' fees incurred in order to contest the deficiency in the instant case. The sole issue for our decision is whether certain selling expenses are deductible from the value of decedent's gross estate as administration expenses pursuant to section 2053(a).1

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