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review the cases cited by the parties in order to complete our
review of the parties’ arguments. Petitioner’s argument relies
on a number of cases where this Court addressed the question of
whether a Tax Court proceeding could be prolonged or extended to
accommodate various types of deductions sought by taxpayers
(usually estates). In Estate of Bahr v. Commissioner, 68 T.C. 74
(1977), the Court considered a question analogous to the one
under consideration. That case involved the question of whether
the Bahr estate was entitled to deduct (under section 2053)
estate tax interest being paid to the Federal Government under
the deferred payment provisions of section 6161. In holding that
such interest was deductible as an administration expense under
section 2053(a)(2), the Court focused on the question of whether
interest on tax liability is, in effect, part of the tax. If so,
it was unquestioned that the estate tax was not deductible.
However, the Court agreed with earlier cases that had held that
the “‘interest on a tax is not a tax, but something in addition
to a tax.’” Id. at 79-80 (quoting Capital Bldg. & Loan
Association v. Commissioner, 23 B.T.A. 848, 849 (1931), and
Pearson v. Commissioner, 4 T.C. 218 (1944), affd. 154 F.2d 256
(3d Cir. 1946)). Under the circumstances of that case, the
interest was otherwise deductible because it met the requirements
of section 2053. Petitioner focuses on Estate of Bahr v.
Commissioner, supra, because, ultimately, the Court permitted the
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