Estate of Doris F. Kahn, Deceased, LaSalle Bank, N.A., Trustee and Executor - Page 1

                                   125 T.C. No. 11                                    


                               UNITED STATES TAX COURT                                


           ESTATE OF DORIS F. KAHN, DECEASED, LASALLE BANK, N.A., TRUSTEE             
                             AND EXECUTOR, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12551-04.               Filed November 17, 2005.            


                    The estate filed Form 706, U.S. Estate (and                       
               Generation-Skipping Transfer) Tax Return (“estate tax                  
               return”).  R issued a notice of deficiency that inter                  
               alia asserted increases to the gross estate by                         
               disallowing a reduction in value of P’s individual                     
               retirement accounts (IRAs) by the expected Federal                     
               income tax liability resulting from the distribution of                
               the IRAs’ assets to the beneficiaries under sec.                       
               408(d)(1), I.R.C. (income tax liability).  This matter                 
               is before us on P’s motion for partial summary judgment                
               under Rule 121(a), contesting R’s disallowance of the                  
               reduction in the value of the IRAs.  R filed a cross-                  
               motion for summary judgment in response to P’s motion.                 
                    Held:  In computing the gross estate value, the                   
               value of the assets held in the IRAs is not reduced by                 
               the anticipated income tax liability following the                     





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