- 8 - Accordingly, no deduction is allowed. Sec. 2053(c)(1)(B); sec. 20.2053-6(b), Estate Tax Regs. IV. Deduction of Debt Owed to Mr. Stewart Is Not Allowed The estate contends that it is entitled, pursuant to section 2053(a)(3), to deduct a debt owed to Mr. Stewart relating to the purported reconciliation agreement, between Mr. Stewart and decedent, to share the income and expenses relating to both properties. An estate may deduct the value of a claim based on a decedent’s promise to pay only if the liability was “contracted bona fide and for adequate and full consideration in money or money’s worth”. Sec. 2053(c)(1)(A); See Estate of Scholl v. Commissioner, 88 T.C. 1265, 1279 (1987). There was no reconciliation agreement. Accordingly, no deduction is allowed. Contentions we have not addressed are irrelevant, moot, or meritless. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011