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the estate to pay petitioner’s elective share, the economic
benefit of those gains inured solely to the estate and its
residuary beneficiaries, Mr. Deutsch and his sisters. Mr.
Deutsch’s purported allocation of capital gains to income,
whatever its effect for estate accounting purposes, had no
practical consequence whatsoever with respect to the relative
entitlements of petitioner and the residuary beneficiaries.
The largest components of the estate's 1989 DNI, totaling
$377,753, were the distributions to the estate from decedent's
IRA's. The bulk of the income from the IRA's represented the
proceeds of decedent's lifetime accumulations of deferred
compensation and were included in estate principal under Florida
law. Fla. Stat. Ann. sec. 738.04(c) (West 1995). Although
petitioner had an economic interest equal to 30 percent of the
value of the IRA’s reflected in the amount of the elective share,
the remaining 70 percent redounded to the benefit of the
residuary beneficiaries. Neither subchapter J, nor the income
tax law generally, provides for allocating income between
petitioner on the one hand, and the estate and its beneficiaries
on the other, on the basis of their proportionate economic
interests therein. Because the quantitative interest of the
estate and its residuary beneficiaries in the income from the
IRA’s is more than twice as large as petitioner’s interest
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