Estate of Edna Pearce Lockett Deceased, David F. Lanier, Personal Representative - Page 25

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             incurred in connection with the operation of the cattle ranch are                                    
             deductible as administration expenses under section 2053.9                                           
                    To reflect the foregoing and concessions,                                                     

             Decision will be entered                                                                             
                    under Rule 155.                                                                               






















                    9 Consistent with respondent's argument that the expenses of                                  
             operating the ranch are not deductible, respondent has also                                          
             argued that the portion of legal fees and accounting fees paid to                                    
             Mr. Lanier and an accounting firm that were attributable to the                                      
             operation of the ranch are not deductible as administration                                          
             expenses.  Respondent's argument explicitly rests on the                                             
             assumption that the expenses incurred in the operation of the                                        
             cattle ranch, in general, are not deductible as administration                                       
             expenses.  Because we hold that the expenses incurred in the                                         
             operation of the ranch are deductible as administration expenses                                     
             under sec. 2053, the legal and accounting fees relating to the                                       
             operation of the ranch are likewise deductible as administration                                     
             expenses.                                                                                            


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Last modified: May 25, 2011