Court of Appeals for the Eleventh Circuit September 10, 1985, No. 84-3598 (Estate of Theis v. Commissioner)

CLARK, Circuit Judge:

This is an appeal from a decision of the tax court, 81 T.C. 741 (1983), finding that the balances due on certain mortgages were not deductible by the appellants’ estates under 26 U.S.C. § 2053. The pertinent facts which were stipulated to are as follows. Mary L. Theis (decedent/wife) died June 29, 1976 in St. Petersburg, Florida.