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As Rick said, during Sarah’s life--she lived 12
years--she was very, very complex with her care. We
had a multitude of people throughout the years who fell
in love with her. People who we didn’t even know
until, you know, later on.
Even after she died, people came to us saying, you
know, what a wonderful little girl she was. And we
wanted to show gratitude towards those people.
The church that we belong to went way out, and
really helped us out during this terrible time.
She had therapist, teachers, just friends, and we
wanted to just show gratitude towards them, and have
the luncheon.
And to be honest with you, we had to hold it in a
place that was large enough, because the church hall,
the reception hall, was unable to handle the volume of
people that showed up for the funeral. So.
On reply brief, the estate then summarizes its position regarding
this item, maintaining “that the funeral reception expense
incurred on the day of decedent’s funeral, because of decedent’s
unique medical circumstances and the support and assistance she
received during her short lifetime is an expense intimately tied
to decedent’s funeral arrangements and is deductible for federal
estate tax purposes.”
Unfortunately, while we applaud the spirit of gratitude and
generosity that apparently animated the decision to sponsor the
funeral luncheon, the record before us is simply inadequate to
establish the event’s deductibility. First, as a practical
matter, both Michigan State law and the Federal regulations
suggest a standard of reasonableness in examining the amount of
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