O. D. McKee and Estate of Anna Ruth McKee, Deceased, R. Ellsworth McKee and Jack C. McKee, Co-Executors - Page 2

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          ending December 31, 1988.  Respondent further determined a                  
          deficiency in decedent's estate's Federal estate taxes in the               
          amount of $1,257,057.                                                       
               After concessions the sole issue for decision is whether               
          decedent's estate may claim as a deduction from the gross estate            
          certain interest expenses under section 2053(a)(2).  Unless                 
          otherwise indicated, all section references are to the Internal             
          Revenue Code in effect at the time of decedent's death, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                     Background                                       
               This case was submitted fully stipulated pursuant to Rule              
          122.  The stipulation of facts and the attached exhibits are                
          incorporated by this reference, and the facts contained therein             
          are found accordingly. Decedent died on June 25, 1989.                      
          Decedent’s residence was in Ooltewah, Tennessee in Hamilton                 
          County, Tennessee, on the date of her death.  Decedent’s two                
          sons, R. Ellsworth McKee and Jack C. McKee, are the executors of            
          her estate.  Decedent and O.D. McKee (decedent’s surviving                  
          spouse) were married at all times relevant hereto.                          
               In 1954, decedent and decedent's spouse acquired McKee Foods           
          Corporation (formally known as McKee Baking Co.) (the Company), a           
          closely held corporation that sells snack foods nationally under            
          the "Little Debbie" trade name.  The Company holds a significant            






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