- 34 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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