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ESTATE OF BAILLY v. COMMISSIONER

Docket No. 9487-81.

81 T.C. 246 (1983)

ESTATE OF PIERRE L. BAILLY, DECEASED, DANTE M. FIORINI, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 6, 1983.

Attorney(s) appearing for the Case

James Curtis Wood, for the petitioner.

Kathleen E. Whatley, for the respondent.

OPINION

DAWSON, Chief Judge:

Respondent determined a deficiency in Federal estate tax against the Estate of Pierre L. Bailly, deceased, in the amount of $380,373.

After concessions by the parties, the issue for decision is whether an estate that has properly elected under section 61661 to pay its estate tax liability in 10 equal annual installments can deduct unaccrued...

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