Estate of Doris F. Kahn, Deceased, LaSalle Bank, N.A., Trustee and Executor - Page 34

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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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