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the estate tax is far removed from the administration of the
estate, which was without assets to pay the liability and which,
accordingly, did not require any further administration or
expense thereof. Moreover, the estate tax liability was
determined and paid and was only to be affected to the extent
that petitioner could show that the interest was allowable under
section 2053.
After a review of case precedent and the parties’ arguments,
we agree with respondent that petitioner has not shown that the
interest here is deductible under section 2053. Accordingly, we
leave for another day the question of whether 20 years is too
long a period to delay entry of decision to accommodate allowable
after-occurring deductions of an estate.
To reflect the foregoing,
An appropriate order will be
issued.
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