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$10,500 of claimed expenses, consisting of: (1) $7,500 fees for
legal services of Dan McCraw, a Hot Springs, Arkansas, attorney,
and (2) $3,000 fees for legal services of George Plastiras, a
Little Rock, Arkansas, attorney.17 On the basis of all the
evidence, we conclude that petitioner has adequately established
that these disputed amounts were necessarily or reasonably
incurred in the administration of the estate. Accordingly, we
hold that the claimed $47,522 of postreturn administrative
expenses is deductible from the value of the gross estate
pursuant to section 2053(a).
To reflect the foregoing and the parties’ concessions,
Decision will be
entered under Rule 155.
17 Included in the $47,522 of postreturn administrative
expenses that petitioner has claimed is $4,899.19 of fees paid to
Joy Gibson (Gibson), a California attorney who handled the
California probate of decedent’s one-half ownership interest in
parcel 2. Respondent concedes that “the expense of bringing the
probate case to clear up title” should be deductible from the
gross estate. Respondent does not dispute that the fees paid to
Gibson were reasonably incurred for this purpose, but contends,
without explanation, that the deductible amount is only
$4,846.49. The parties have stipulated that the estate paid
Gibson $4,899.19. We deem respondent to have conceded that
$4,899.19 is deductible from the gross estate.
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