- 3 - administration expenses, how much Trust B distributed to Trust C, or whether the trust agreement required Trust B to distribute those amounts. Id. at 345. On remand, the issue for decision is whether it was necessary for Trust B to hold Ripplestone after March 16, 1990, to ensure that it could pay decedent's estate tax. We hold that it was not. Thus, the expenses to maintain and sell Ripplestone after March 16, 1990, were not necessary administration expenses. We conclude that the estate may not deduct expenses to maintain and sell Ripplestone after March 16, 1990. The parties filed briefs and supplemental stipulations of fact after the Court of Appeals for the Sixth Circuit remanded this case. Petitioners asked for oral argument if we are inclined to disallow the claimed deductions. We conclude that oral argument is not necessary to decide the issue before us. Unless otherwise noted, section references are to the Internal Revenue Code in effect during the time relevant to this case. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT We incorporate by reference our findings of fact in Estate of Millikin v. Commissioner, T.C. Memo. 1995-288, except for those which the parties agree should be modified. Some additional facts have been stipulated and are so found.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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