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estate taxes will not reduce the marital deduction." Estate of
Street v. Commissioner, supra at 728. The court in Estate of
Street further noted that its holding was mandated by, and
consistent with, section 2056(b)(4) and section 20.2056(b)-4(a),
Estate Tax Regs. We find that Estate of Street dealt solely with
the calculation of the marital deduction and is not relevant to
the current matter.
Respondent further relies on Estate of Sachs v.
Commissioner, 856 F.2d 1158, 1160 (8th Cir. 1988), revg. 88 T.C.
769 (1987), as additional support for her argument that the
deduction for interest accruing from December 31, 1991, to
January 15, 1993, should be disallowed. The issue in Estate of
Sachs was whether an estate was entitled to a deduction for
certain income taxes paid as a result of a net gift made by the
decedent prior to his death. The U.S. Court of Appeals for the
Eighth Circuit had previously decided in another case that the
payment of gift taxes by the recipient of a gift results in
income to the donor. This holding was upheld by the U.S. Supreme
Court and the Sachs estate paid the income taxes that were owed
as a result of this decision and also claimed these taxes as an
administration expense.
The Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat.
494, in certain circumstances granted relief from income tax for
donors of net gifts made prior to a specified date. As a result
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