OPINION
STERRETT, Chief Judge:
By notice of deficiency dated January 10, 1986, respondent determined a deficiency in petitioner's Federal income tax for the fiscal year ended May 31, 1983, in the amount of $50,944. The only issue for decision in this case is whether a deduction claimed by petitioner for an interest expense, incurred and paid by petitioner on the unpaid balance of a Federal estate tax liability deferred...
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