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          2003.  Respondent contends that the Farm Credit loan was                    
          unnecessary because the estate could have paid the annual                   
          installments of estate taxes from the proceeds of the sale of               
          estate assets or from the interest or principal on the $143                 
          million in notes, due on January 31, 2004, without borrowing                
          funds from Farm Credit.                                                     
               We disagree.  After the executors elected to pay the estate            
          tax in 10 annual installments, respondent’s examiner told the               
          estate’s counsel that the estate’s transfer of corporate assets             
          to HG and its subsidiaries threatened the estate’s ability to               
          continue to defer payment of estate tax under section 6166, thus            
          making acceleration of estate tax under section 6166(g) likely.             
          Subsequently, on the advice of estate tax counsel, the executors            
          decided to pay the estate tax in full.  Thus, we disregard the              
          fact that the estate had elected to pay the estate tax in 10                
          annual installments in deciding whether the Farm Credit loan was            
          necessary.                                                                  
               7.   Whether, Under New York Law, the Executors Were                   
                    Required To Have the Foundation Return Assets to the              
                    Estate To Pay Estate Tax                                          
               Respondent contends that the loan was unnecessary because              
          the executors were required, under New York law, to demand that             
          the foundation return to the estate the amount of assets needed             
          to pay estate taxes and administration expenses.                            
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