-53-
454 (1964) (Court upheld disallowance of section 2053 deduction
for amount allegedly owed by deceased taxpayer to deceased
spouse's estate; no evidence of an express or implied promise to
repay; no proof that deceased taxpayer knew the amounts drawn by
trustee for her benefit on Special Account were not her own),
affd. sub nom. Levin v. Commissioner, 355 F.2d 987 (5th Cir.
1966). We therefore sustain respondent's determinations in this
issue.
Issue 5. Whether the Present Value of the Cost of Maid Service
for 5 Years May Be Deducted From the Value of the Estate as an
Administration Expense
At the time of her death, decedent owned an undivided one-
half interest in a condominium as a tenant-in-common with Mrs.
Nathan. The executors have not distributed decedent's interest
in the condominium, nor have they offered decedent's interest in
the condominium for sale, and out-of-town guests stay there from
time to time.
Decedent and Mrs. Nathan each employed maids; decedent had
employed her maid, Mary, for 15 years prior to her death. Mrs.
Nathan continues to occupy the condominium and continues to
employ her own maid. The executors now employ Mary to clean and
wax decedent's furniture remaining in the condominium "just so
that it [doesn't] crack", and to do "whatever [is] needed to
maintain the property."
Petitioner deducted the present value amount of 5 years of
Mary's future services, $20,501, from the gross value of the
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