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ESTATE OF WHITTLE v. COMMISSIONER

Docket Nos. 13171-89, 21508-89.

97 T.C. 362 (1991)

ESTATE OF RUBY MILLER WHITTLE, DECEASED, CITIZENS NATIONAL BANK OF DECATUR, TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT JOHN G. AND RUBY M. WHITTLE TRUST DATED 3/17/1981, CITIZENS NATIONAL BANK OF DECATUR, TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 19, 1991.

Attorney(s) appearing for the Case

Thomas S. Sly and Darrell A. Woolums, for the petitioners.

Richard A. Stone, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $19,584 in the estate tax of Ruby Miller Whittle. The issues for decision are: (1) Whether, in computing the credit for tax on prior transfers pursuant to section 2013,1 the value of property transferred to the decedent, as sole heir and surviving joint tenant of her husband John G. Whittle, must be reduced by the amount of interest assessed and paid pursuant...

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