- 37 - 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 ofPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011