(decedent, before death, created LLC and transferred funds to LLC derived from sale of stock in decedent's closely-held business which was undergoing buy-out from Pepsi, Corp.; LLC worth $317.9 million (primarily cash) in net asset value; decedent's children redeemed their interests in LLC before decedent's death resulting in decedent's estate holding 70.42 percent voting interest and 70.9 percent equity in LLC; decedent's estate had liquid assets of over $19 million; anticipated estate and GSTT tax was $26 million, and estate borrowed $10.75 million from LLC in return for installment note with initial payment deferred until 2024 (18 years) with interest set at 9.5 percent (at time when long-term AFR was 4.61 percent); estate claimed discount for decedent's LLC interest of 31.7 percent which court rejected and allowed 7.5 percent discount that IRS conceded - estate's expert based analysis on companies that derived profits primarily from active business operations, unlike decedent's LLC; court noted that while estate tax deduction for estate administration expenses is allowed, prior decision in Estate of Gilman v. Comr., T.C. Memo. 2004-286 which allowed estate tax deduction for interest if loan necessary to raise money to pay estate tax without liquidating estate assets at forced-sale prices inapplicable; in present case, court noted that LLC was cash-rich and that estate had power to require LLC to make pro-rata distribution to members, thus eliminating need to sell assets; court also noted that loan would deplete company's cash similar to distribution; $71.4 million interest deduction disallowed; case also unlike Estate of Duncan v. Comr., T.C. Memo. 2011-255 and Estate of Kahanic, T.C. Memo. 2012-81 in which deduction was allowed in cases where estates were much less liquid).