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examined the issue of whether to discount the value of
installment notes in decedent’s estate for future income taxes
that the beneficiaries of those notes would pay on the income in
respect of a decedent included in future installments. We
determined that the statutory scheme in section 691 obviated the
need to give the taxpayer any further relief. Id. at 226.
Section 691(a)(1) provides that “all items of gross income in
respect of a decedent * * *shall be included in the gross income,
for the taxable year when received”. Section 691(a)(3) provides
that such income in the hands of the person acquiring a right to
it from decedent will be treated in the same manner as it would
have been in the hands of decedent. We noted that if the statute
stopped here, installment notes transmitted by a decedent at his
death would be included in decedent’s estate at the fair market
value provided under sections 2031 and 2033, and each portion of
the future installment payments which represented taxable gain
would be subject to an income tax in the year of receipt. Id. at
226. However, we further observed that section 691(c) grants
some relief from the double taxation by providing that the
recipient of income in respect of a decedent may deduct that
portion of the estate tax levied on decedent’s estate which is
attributable to the inclusion of the right to such income in
decedent's estate. We concluded therefore in Estate of Robinson
v. Commissioner, supra at 226-227:
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