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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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