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of their cash flows.") The advance payment of executor's
commissions was for the sole benefit of Mr. Baird and Ms.
Groetzinger and was not necessary for the administration of the
estate. Accordingly, we hold that the fees relating to the
payment of advance executor commissions are not deductible.
The remaining services provided by HBW were essential to the
administration of the estate. Accordingly, we hold that the
remainder of the fees are allowable under the regulations and,
pursuant to section 2053(a)(2), are deductible from the gross
estate.
We have considered the other arguments made by the parties
and found them to be either irrelevant or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011