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          entitled to tax benefit resulting from sale of capital asset);              
          McKee v. Commissioner, 35 B.T.A. 239, 242 (1937) (trustees who              
          realized tax savings by selling, rather than redeeming, matured             
          bonds acted in the best interests of the trusts).  We do not                
          substitute our judgment for decisions of the executors to                   
          complete the restructuring in January 1999.  See Estate of Todd             
          v. Commissioner, 57 T.C. 288 (1971); Estate of Thompson v.                  
          Commissioner, T.C. Memo. 1998-325; McKee v. Commissioner, T.C.              
          Memo. 1996-362; Estate of Sturgis v. Commissioner, T.C. Memo.               
          1987-415.                                                                   
               Second, the executors did not foresee the decrease in Gilman           
          Building Products’ annual net positive cashflow from more than              
          $40 million per year in years before 2000 to $3.5 million in                
          2000.  The decline in Gilman Building Products’ financial                   
          condition contributed to HG’s inability to pay the estate nearly            
          $23 million of interest due in 2002.  In light of the unforeseen            
          decline in Gilman Building Products’ financial condition and HG’s           
          and its subsidiaries’ inability to fully pay interest due on the            
          notes in 2002, it was necessary for the estate to borrow funds in           
          2002.                                                                       
               6.   Whether the Farm Credit Loan Was Unnecessary Because              
                    the Executors Had Elected To Pay Estate Tax in 10                 
                    Annual Installments                                               
               The executors elected on April 1, 1999, to pay Federal and             
          New York estate taxes in 10 annual installments beginning in                
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