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H. Notices of Deficiency
Respondent issued the notices of deficiency in this case on
February 25, 1993. In the notices, respondent determined that
the value of Ripplestone was $3.7 million, the amount for which
it was appraised on July 28, 1989, rather than $3.2 million, the
amount that the estate reported on the estate tax return.
II. OPINION
A. Background
Petitioners contend that they may deduct from the value of
the gross estate the costs to maintain and sell Ripplestone that
they incurred after March 16, 1990, under section 2053(b).3
1. Deductibility of the Costs of Maintaining and Selling
Ripplestone Under Section 2053(b)
Petitioners may deduct from the value of the gross estate
the costs of maintaining and selling Ripplestone after March 16,
1990, under section 2053(b) if (a) Ripplestone is included in the
3 Sec. 2053(b) provides:
SEC. 2053(b). Other Administration Expenses.--Subject
to the limitations in paragraph (1) of subsection (c),
there shall be deducted in determining the taxable
estate amounts representing expenses incurred in
administering property not subject to claims which is
included in the gross estate to the same extent such
amounts would be allowable as a deduction under
subsection (a) if such property were subject to claims,
and such amounts are paid before the expiration of the
period of limitation for assessment provided in section
6501.
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