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ESTATE OF MORSE v. COMMISSIONER

Docket No. 7740-74.

69 T.C. 408 (1977)

ESTATE OF FRANKLIN A. MORSE, DECEASED, THE FIRST NATIONAL BANK OF SOUTHWESTERN MICHIGAN, ADMINISTRATOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 6, 1977.

Attorney(s) appearing for the Case

James F. Thornburg, Stephen A. Seall, and Brian J. Lake, for the petitioner.

Elsie Hall, for the respondent.

DRENNEN, Judge:

Respondent has determined a $30,761.49 deficiency in the amount of Federal estate tax due from petitioner.

The principal issue presented is whether the present value of annual payments of $12,000 per year to the decedent's surviving spouse is deductible by petitioner under section 2053(a)(3), I.R.C. 1954,1 as a claim against the estate "contracted bona fide and for an adequate and full consideration in money...

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