O. D. McKee and Estate of Anna Ruth McKee, Deceased, R. Ellsworth McKee and Jack C. McKee, Co-Executors - Page 31

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          Provident.  The Company repaid its note to decedent's estate on             
          January 15, 1993, at which time the estate also repaid the                  
          Provident Loan.  Respondent asserts that the elimination of a               
          claimed expense should also eliminate its deductibility, citing             
          Estate of Street v. Commissioner, 974 F.2d 723 (6th Cir. 1992),             
          affg. in part and revg. in part T.C. Memo. 1988-553.  We                    
          disagree.                                                                   
               Respondent contends that the interest incurred on the                  
          Provident Loan during the post mortem period in which the Company           
          paid the exact amount of interest on its notes to decedent's                
          estate had no negative impact on the net estate.  Respondent                
          quotes the following passage from Estate of Street to support her           
          position:  "'To pay the interest on the deferred taxes out of               
          income of the estate would neither increase nor decrease the                
          principal of the estate as it was at the time of decedent's                 
          death.'"  Id. at 727-728 (quoting Estate of Richardson v.                   
          Commissioner, 89 T.C. 1193, 1205 (1987)).  The issue in Estate of           
          Street was whether the marital deduction has to be reduced by               
          interest on deferred taxes and other administration expenses that           
          were paid out of the income generated by the marital share of the           
          estate.  Explaining the meaning of the Estate of Richardson                 
          decision, the Court of Appeals in Estate of Street stated:                  
          "Therefore, Estate of Richardson stands only for the proposition            
          that the payment, from income, of interest on inheritance and               






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