T.C. Memo. 1998-325 UNITED STATES TAX COURT ESTATE OF LEWIS S. THOMPSON, III, DECEASED, SYNOVUS TRUST COMPANY, SUCCESSOR EXECUTOR TO SECURITY BANK AND TRUST COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14929-96. Filed September 16, 1998. D died testate on Feb. 19, 1992. At the time of his death, D owned a 3,489-acre parcel of real property (CMP), which was used to produce merchantable timber and crops and as a hunting preserve. P borrowed funds from D's insurance trust for purposes of paying Federal and State estate taxes and for the maintenance of CMP pending the resolution of this dispute. On a timely filed Federal estate tax return, P reported the value of CMP at its fair market value (FMV). P also made a valid protective election for special use valuation of CMP under sec. 2032A, I.R.C. In addition, P deducted the interest incurred on the borrowed funds from the value of D's gross estate as an administrative expense under sec. 2053(a)(2), I.R.C. On a timely filed amended estate tax return, P claimed that it is entitled to a refund for overpaymentPage: 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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