- 34 - 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.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34
Last modified: May 25, 2011