Estate of Marguerite S. Millikin, Deceased, Quentin Alexander, Executor, and Severance A. Millikin Trust B, Society National Bank, F.K.A. Ameritrust Company, Trustee - Page 3

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            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.                                     





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