- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011