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consequences of distributing the assets in the IRAs because the
buyer would be purchasing the securities, not the IRAs
themselves. Unlike the other cases the estate has cited, the tax
liability associated with the distribution of the IRAs would not
be passed on to the buyer. In addition, section 691(c) provides
relief from the double taxation that would be imposed on the
benficiaries of the IRAs in this case. In conclusion, the series
of comparisons that the estate has crafted to convince us that it
is entitled to a reduction in the value of its IRAs for the
income tax consequences to the beneficiaries is unconvincing.
The correct result in this case is to value the IRAs based on
their respective account balances on the date of decedent’s
death.
Consistent with the preceding discussion, we conclude that
petitioner’s motion for partial summary judgment will be denied,
and respondent’s cross-motion for summary judgment will be
granted.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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