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          loan was not necessary to the extent that funds were borrowed               
          beyond January 2004, or were to be used to pay unidentified                 
          miscellaneous administration expenses or Bergreen’s and Davis’s             
          compensation.  Thus, the estate may deduct a portion of the                 
          interest and closing costs that accrued from October 18, 2002, to           
          January 31, 2004; the deductible portion of the interest and                
          costs is allocable to the portion of the loan used to pay the               
          estate’s Federal and State estate taxes.                                    
          B.   Whether the Estate May Deduct $3,507,723 in Additional                 
               Administration Expenses                                                
               1.   Contentions of the Parties and Background                         
               The executors paid administration expenses of: (a) $244,074            
          in legal fees to Cullen & Dykman; (b) $1,556,164 in consulting              
          fees to Price Waterhouse; (c) $633,347 in legal fees to                     
          Fensterstock & Partners; (d) $826,364 in consulting fees to Pearl           
          Meyer; and (e) $1,247,775 in legal fees to Carter Ledyard,                  
          counsel for the estate, for a total of $4,507,723.  The executors           
          allocated those expenses to income.  Respondent does not dispute            
          that these amounts were paid to lawyers, accountants, and Pearl             
          Meyer, or that the estate had income of $2,844,738.  Respondent             
          concedes that the estate may deduct legal expenses of $1 million            
          that the executors paid from income.                                        
               The estate contends that it may deduct additional expenses             
          of $3,507,723 (i.e., that much more than the $1 million                     
          respondent concedes) because those expenses are administration              
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