Estate of Delores E. Lasarzig, Deceased, Wells Fargo Bank, Trustee - Page 19




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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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Last modified: May 25, 2011