- 36 - ing that residence, including certain utility expenses (i.e., telephone, home heating fuel, and electricity provided at dece- dent’s residence19), and in distributing those assets are deduct- ible under section 2053 and the regulations thereunder. See sec. 20.2053-3(d)(1), Estate Tax Regs. In addition, on the record before us, we find that certain expenses incurred for additional death certificates, rental of a safe deposit box, postage, and insurance on decedent’s residence are deductible under those provisions. Based on our examination of the entire record in this case, and bearing in mind that the estate has the burden of proving its entitlement under section 2053(b) to the miscellaneous adminis- tration expenses claimed, we find that the estate is entitled to deduct $3,100 as administration expenses.20 19Schedule L shows electric bills at decedent’s residence for the period May 19, 1994, through Sept. 20, 1994, totaling $1,197.41. For example, the electric bill for the period May 19, 1994, through June 21, 1994, was $356.24, and the electric bill for the period June 21, 1994, through July 22, 1994, was $451.52. Although the periods to which those bills relate covered late spring and early summer 1994, there is no explanation in the record why those bills were so high. One possible explanation is that someone was living at the house during those periods. Without further explanation as to why it was necessary to incur such high electric bills during the period May 19, 1994, through Sept. 20, 1994, the Court will allow only $100 per month for each of the four months of electric bills covered by that period, or a total of $400. The Court will allow in full the amount of the remaining electric bills that were not conceded by respondent. 20The expenses allowed by the Court consist of all or cer- (continued...)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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