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ESTATE OF SCOFIELD v. COMMISSIONER

Docket No. 9606-77.

41 T.C.M. 227 (1980)

T.C. Memo. 1980-470

Estate of Francis Ned Scofield, Deceased, Granville O. Scofield, Executor v. Commissioner.

United States Tax Court.

Filed October 21, 1980.

Attorney(s) appearing for the Case

Richard L. Carico, One Maritime Plaza, San Francisco, Calif., for the petitioner. Milton B. Blouke, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $54,056.00 in the Federal estate tax of the Estate of Francis Ned Scofield. The only issue to be decided is whether the estate is entitled to any deduction under section 2053 of the Internal Revenue Code of 19541 for a lien upon assets of the estate, which resulted from the decedent's guaranty of bank loans made to his son.

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