Estate of Sarah M. Davenport, Deceased, Richard Davenport, Executor - Page 37

                                       - 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 of             






Page:  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