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was not required to redeem enough of decedent's shares of class B
stock to provide funds to pay all death taxes and all the
estate's other actual or potential liabilities when due. It is
not our province, and we are not prepared, to second guess the
business judgments of the executors, for the executors have not
been shown to have acted other than in the best interests of the
estate. We believe that the executors' decision not to make a
section 6166 election was prudent because, among other reasons,
the estate benefited from increases in value to the Company stock
and, consequently, decedent's estate was in a better situation to
face contingencies such as an increased estate or gift tax
liability. These loans allowed the estate to pay its Federal
estate obligation in full shortly after decedent's death.
Decedent's estate is entitled to a deduction for the interest
expenses incurred on these loans under section 2053(a)(2). We
have considered all other arguments made by petitioners and
respondent and find them to be either irrelevant or without
merit.
Based on the foregoing,
Decision will be entered under
Rule 155.
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