Estate of Constance R. Grant - Page 34




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          incurred in preserving and distributing the estate’s assets.  The            
          record is devoid of any evidence explaining what Mr. Grant and               
          Ms. Adams did when they traveled over 2,800 miles in Maryland.               
               The estate claims that virtually all of the other expenses              
          at issue were incurred (1) “to maintain, or prevent some degrada-            
          tion in, the condition of” decedent’s residence; (2) “for repairs            
          to enhance the salability of” decedent’s residence; and (3) “for             
          selling” decedent’s residence.16  We address first the estate’s              
          contention that the sale of decedent’s residence was necessary in            
          order to pay taxes because “the cash in the estate * * * [was]               
          insufficient” to do so and that therefore the expenses for the               
          last two purposes claimed satisfy section 20.2053-3(d)(2), Estate            
          Tax Regs.  We disagree.  While decedent’s estate might not have              
          had sufficient cash to pay taxes, it had more than enough cash               
          and liquid cash type assets to pay such taxes.  In this connec-              
          tion, the estate tax return reported as part of decedent’s gross             
          estate, inter alia, five money market mutual funds with total                
          funds of $121,603; a checking bank account with funds of $31,274;            
          and a money market bank account with funds of $17,879.  The                  
          estate tax return showed estate tax due of $60,118, claimed a                




               16Although not altogether clear from the record, it appears             
          that, except for decedent’s residence, most of decedent’s nonpro-            
          bate property was distributed by the end of 1994.                            





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