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settled as of the date of the testator's death." This principle
is followed in cases involving the valuation of a claim that is
valid and fully enforceable on the date of a decedent's death.
See Estate of Smith v. Commissioner, 108 T.C. 412, 419 (1997),
supplemented by 110 T.C. 12 (1998). In cases where the
decedent's creditor has only a potential, unmatured, contingent,
or contested claim that requires further action before it becomes
a fixed obligation of the estate, postdeath events warrant
consideration. Id. Where a claim is disputed, contingent, or
uncertain as of the date of a decedent's death, the estate is not
entitled to a deduction until the claim is resolved and it is
determined what amount, if any, will be paid. Id.
We have held that a claim that is valid and enforceable at
the date of a decedent's death must remain enforceable in order
for the estate to deduct the claim. Technical claims that
disappear in the light of subsequent circumstances should not be
allowed. Thus, postdeath events must be taken into consideration
in determining the enforceability of a claim that a creditor
fails to make and preserve within the time allowed by local law.
See Estate of Hagmann v. Commissioner, 60 T.C. 465, 469 (1973),
affd. 492 F.2d 796 (5th Cir. 1974).
Petitioner argues that the income tax liability that was
timely paid was a valid and enforceable claim on the date of
decedent's death, and, therefore, postdeath events are not to be
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