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credit for State death taxes of $23,911, and claimed $53,583 of
deductions.
On the record before us, we find that the estate had suffi-
cient cash and liquid cash type assets to pay not only taxes but
also all of its debts and expenses without selling decedent’s
residence. We therefore reject the estate’s position that the
sale of decedent’s residence satisfies section 20.2053-3(d)(2),
Estate Tax Regs., because that sale was necessary to pay taxes.
We further find on the instant record that the estate has failed
to show that any of the expenses which it claims were incurred
“for repairs to enhance the salability of” decedent’s residence17
and “for selling” that residence18 are deductible under section
2053.
Nonetheless, we believe on the record presented that it was
not possible to distribute all of decedent’s property, including
decedent’s residence and the household and other personal effects
located at that residence, immediately after decedent’s death.
Consequently, we find that certain expenses incurred in maintain-
17On brief, the estate indicates that the expenses “for
repairs to enhance the salability of” decedent’s residence are
set forth in Schedule L as items 6, 8, 9, 12, 13 (to the extent
of $750), 14, 15, 19, 21, 23, 24, 27, 28, 30, 31, 34, 35, 37, 39,
41, 44, 45, 49 (to the extent of $18), 50, 52, 55, and 57.
18On brief, the estate indicates that the expenses “for
selling” decedent’s residence are set forth in Schedule L as
items 16, 32, 33, and 47.
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