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GRAY v. COMMISSIONER

Docket Nos. 18526-93, 18537-93, 18538-93.

73 T.C.M. 1940 (1997)

T.C. Memo. 1997-67

Jewell E. Gray, Donor, Deceased and Estate of Jewell E. Gray, Deceased, Jewell Mae Detjen, Personal Representative, et al. v. Commissioner.

United States Tax Court.

Filed February 5, 1997.

Attorney(s) appearing for the Case

Daniel C. Johnson and Philip A. Diamond, Orlando, Fla., for the petitioner. James F. Kearney, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a deficiency in petitioner's estate tax of $1,179,865.2

After concessions, we must decide the following issues:

1. Whether transfers totaling $1,724,198 from Beth W. Corp. to or on behalf of decedent are loans. We hold that the transfers are not loans and that petitioner may not deduct the transfers as a claim against the estate.

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