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 11

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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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