O. D. McKee and Estate of Anna Ruth McKee, Deceased, R. Ellsworth McKee and Jack C. McKee, Co-Executors - Page 30

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          especially in view of respondent's proposed assertion of                    
          increased deficiencies.                                                     
               Decedent incorporated the provisions of Tenn. Code Ann. sec.           
          35-50-110 in her will, thus giving her executors a wide range of            
          powers, including the power to obtain loans on behalf of the                
          estate and to pledge assets to secure those loans.  There is                
          nothing in the will to suggest decedent intended to restrict this           
          specifically granted authority.  A testator's intent "must be               
          ascertained from that which he has written into the will, and not           
          from what some interested party supposes that he intended to do."           
          Davis v. Price, 226 S.W.2d 290, 292 (Tenn. 1949).  The estate's             
          interest expenses are deductible as administration expenses under           
          section 2053(a)(2).                                                         
          II. Respondent's Alternative Theory.                                        
               Respondent alternatively argues that decedent's estate is              
          not entitled to a deduction under section 2053(a)(2) for interest           
          expense accruing on loans during the period in which a promissory           
          note from the Company, on which the estate was payee, produced              
          interest income exactly offsetting the Provident Loan interest              
          expense.  Decedent's estate sold a substantial block of class B             
          stock to the Company on December 30, 1991.  In exchange,                    
          decedent's estate received a cash payment and a promissory note,            
          the terms of which were identical to the terms of the promissory            
          note which the estate had previously executed in favor of                   






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