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sold all of its assets, with the exception of the shopping center
parcels, so it did not unreasonably refuse to sell assets; (2) it
is not impermissible for an estate to incur expense (in this case
interest) to preserve property for the benefit of the
beneficiaries; (3) the loan was secured in order to vest good
title in the beneficiaries because the proceeds were used to pay
off the estate tax and remove the Government’s lien from the
shopping center realty; (4) because the shopping center property
had a value of more than double the outstanding tax liability, it
would have been necessary to sell only a fractional interest and
a severe discount would have resulted. If the entire property
had been sold, the expenses of sale would have had to be borne by
the portion that did not go to pay the estate tax, as well as the
portion that was used for that purpose; (5) the trustee/
beneficiaries believed that the shopping center would increase in
value and they should be allowed to borrow against, as opposed to
selling, the property; and (6) the situation here is analogous to
that of a trust holding a family farm for which sections 2032A
and 2057 permit the type of relief petitioner seeks. Those
estate tax provisions indicate a general congressional intent to
preserve estates’ interests in certain family-owned businesses.
Although we consider the cases cited by the parties in order
to reach our conclusion, the parties’ interpretations of the
cases appear generally to favor the allowance of the deduction of
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