- 30 - 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 administrationPage: 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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