- 2 - 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 significantPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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