Estate of Duncan v. Comr., T.C. Memo. T.C. Memo. 2011-255

(trust was residual beneficiary of estate and trust assets were included in gross estate; trust borrowed money to allow estate to pay estate taxes; estate entitled to administrative expense deduction for interest on the loan; loan was bona fide debt and ascertainable with reasonable certainty and was actually and reasonably necessary - estate not required to sell assets at a discount to come up with the funds to pay estate tax; terms of loan reasonable).