Proposed Regulations for §2053

Steve R. Akers (Bessemer Trust, Dallas, Texas) has written ProposedRegulations Limiting Estate Tax Deductions for Uncertain Claims Against Decedentsand Other Administration Expenses Under §2053 for the RPPT, May 2007issue.

Here is the introduction:

The IRS has issued proposedregulations dealing primarily with the deductibility of claims against adecedent’s estate that are uncertain in amount at the date of death. Thegeneral approach for such contingent or uncertain claims is that a deduction isallowed only as payments are actually made by the estate, but there is anexception for estimated amounts that are ascertainable with reasonablecertainty.