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provided the following touchstone: “The basis of this deduction
is the necessity of the expense in connection with the decedent’s
funeral.” Estate of Berkman v. Commissioner, T.C. Memo. 1979-46;
see also Estate of Tuck v. Commissioner, T.C. Memo. 1988-560 (“As
we interpret the term ‘funeral expenses’, it means expenses
incurred in connection with the decedent’s funeral.”).
The record contains no documentary evidence with respect to
the claimed funeral luncheon expense. At trial, decedent’s
parents provided the information set forth below. Mr. Davenport
testified in a colloquy with counsel:
Q Now I’d like to draw your attention to
Sarah’s funeral. In connection with the funeral, was
there a reception after the funeral?
A Yes, there was.
Q And what was the purpose of that reception?
A In large part it was to say, Thank you to a
lot of people in our family, teachers, other healthcare
professionals that worked with us and Sarah over the
years.
Q And were these individuals invited to the
funeral?
A Yes, they were.
Q And these were people that had rendered care
to her. Did she require a great deal of care?
A Yes, she did.
Ms. Weiss-Davenport was similarly asked what she “felt the
purpose of that reception was”, and she responded:
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