O. D. McKee and Estate of Anna Ruth McKee, Deceased, R. Ellsworth McKee and Jack C. McKee, Co-Executors - Page 27

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          not by liquidity problems or valuation disputes, but by the sale            
          of the mansion, and thus had been unduly prolonged.  See sec.               
          20.2053-3(d)(1), Estate Tax Regs. (expenses of caring for and               
          preserving property will not be allowed "for a longer period than           
          the executor is reasonably required to retain the property").               
               The facts in this case are distinguishable from those of               
          Hibernia Bank.  In this case, the most valuable estate assets               
          were the shares of class B and class E stock in the Company.  The           
          Company was neither able nor required to redeem enough of these             
          shares to provide funds to pay all death taxes and all the                  
          estate's other actual or potential liabilities when due.                    
          Further, the executors believed that the Company stock was likely           
          to increase in value.  Accordingly, borrowing funds, rather than            
          selling stock, allowed decedent's estate to more easily meet its            
          burdens by taking advantage of the increasing value of the stock.           
          The Company's shares of stock were less marketable than in                  
          Hibernia Bank as they were not publicly traded.  While it is true           
          that the executors of decedent's estate were also directors of              
          the Company, this fact alone will not make the loans unauthorized           
          as the executors have been shown to have acted in the best                  
          interest of decedent's estate.                                              
               Decedent's estate further relies on Estate of Todd v.                  
          Commissioner, 57 T.C. 288 (1971).  In Estate of Todd, the estate            
          borrowed $300,000 from a private source.  The estate consisted              






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