United States Tax Court May 28, 1964, Docket No. 3634-62 (Caplan v. Commissioner)

lead-opinion

Bruce, Judge:

Respondent determined a deficiency in the estate tax of petitioner in the amount of $50,546.90. The sole issue is whether the amount of $125,584.90 is deductible by petitioner as a debt under section 2053 of the Internal Revenue Code of 1954.

FINDINGS OF FACT

The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.