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ESTATE OF GIBSON v. COMMISSIONER

Docket No. 3511-74.

65 T.C. 813 (1976)

ESTATE OF KATE M. GIBSON, DECEASED, GEORGE W. GIBSON, JR., EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 26, 1976.

Attorney(s) appearing for the Case

George W. Gibson, Jr. (executor), for the petitioner.

Robert E. Glanville, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in the estate tax of the Estate of Kate M. Gibson, deceased, George W. Gibson, Jr., executor, in the amount of $15,421.19.

The only issue for decision is whether the estate is entitled to a deduction for a usufructuary accounting as a claim against the estate under section 2053, I.R.C. 1954,1 in the amount of $59,517.15, where the forced heirs (children) of the decedent's...

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