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ESTATE OF WHELESS v. COMMISSIONER

Docket No. 10100-75.

72 T.C. 470 (1979)

ESTATE OF WILLIAM M. WHELESS, SR., DECEASED, W. M. WHELESS, JR., W. M. POWELL, JR., CO-INDEPENDENT EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 11, 1979.

Attorney(s) appearing for the Case

Glenn H. Johnson, for the petitioners.

William D. Peltz, for the respondent.

OPINION

DRENNEN, Judge:

Respondent determined a deficiency of $54,816.02 in petitioner's estate tax. The only issue presented in this case is whether interest paid by the executors which had accrued subsequent to the date of death on those debts contracted by the decedent which were not due and owing on or before the date of death constitute deductible administration expenses within the meaning of section...

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