- 24 - administration expenses. The estate contends that a reasonable estimate satisfies the requirement of section 2053 that expenses be necessary for the administration of the estate because (a) only an estimate of the amount of the loan was possible when the estate obtained the loan, and (b) the estate’s obligation to pay the $38 million loan and interest thereon is fixed. Thus, the estate contends, it may deduct the interest on that portion of the loan to be used to pay miscellaneous expenses of $816,175. We disagree because the record does not show what expenses are included in the $816,175 amount. Thus, these expenses may no more be estate expenses than was the compensation for Bergreen and Davis. See paragraph A-2, above. 4. Whether the Estate Was Illiquid When It Borrowed Funds From Farm Credit Respondent contends that, after the estate paid the cash bequests in May 1998, it had enough liquid assets with which to pay its estate taxes and administration expenses and thus did not need the Farm Credit loan. We disagree. After payment of the cash bequests and before the restructuring, the estate had more than enough assets to pay administration expenses and Federal and State estate taxes. However, these assets were illiquid. Every witness, including respondent’s witnesses Rossellini, Justin Feldman, and John J. Kennedy (all of whom were independent directors on the board ofPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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