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Estate of Shapiro v. Commissioner of Internal Revenue

111 F.3d 1010 (1997)

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Estate of Shapiro v. Commissioner of Internal Revenue

United States Court of Appeals for the Second Circuit

111 F.3d 1010 (1997)

Facts

The estate of Benjamin Shapiro (the Estate) (plaintiff) owed approximately $1,200,000 in estate taxes and deferred payment under § 6166(a) of the Internal Revenue Code (IRC), which allowed a closely held business to pay estate taxes in installments to avoid the liquidation of the business. The Estate also attempted to deduct interest payments made under § 6166 as an administrative expense. Section 2053(a)(2), which governs the deduction of annual interest payments, does not allow the deduction of interest that has not accrued. Revenue Procedure 81-27, 1981-2 C.B. 547 (the revenue procedure), however, allows the deduction of interest payments when they are made. The Estate attempted to deduct its interest payments pursuant to the revenue procedure. The Internal Revenue Service (IRS) (defendant) disallowed the interest-expense deductions. The Estate paid the interest and requested a refund. The IRS refused the refund. The Estate petitioned the United States Tax Court for a redetermination, and the tax court upheld the IRS. The Estate appealed.

Rule of Law

Issue

Holding and Reasoning (Calabresi, J.)

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