O. D. McKee and Estate of Anna Ruth McKee, Deceased, R. Ellsworth McKee and Jack C. McKee, Co-Executors - Page 34

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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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