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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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