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ESTATE OF MELVILLE v. COMMISSIONER

Docket No. 22027-90.

66 T.C.M. 1076 (1993)

T.C. Memo. 1993-484

Estate of Kate Clark Melville, Deceased, Bank of New York, Executor v. Commissioner.

United States Tax Court.

Filed October 20, 1993.

Attorney(s) appearing for the Case

Jon Holden Adams, 35 Market St., Poughkeepsie, N.Y., for the petitioner. Pietra Pastore, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax of $53,744 and an addition to tax under section 6651(a)(1) of $13,436.1 The deficiency was due to the disallowance of certain administration expense deductions.

After concessions,2 the issues for decision are:

(1) Whether petitioner, the estate of Kate Clark...

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