Marshall Naify Revocable Trust, et al. v. United States, No. C 09-1604, 2010 U.S. Dist. LEXIS 101312 (N.D. Cal. Sept. 9, 2010)

(estate could not deduct from gross value of estate the amount of capital gain tax decedent owed at time of death to state of California because it was not ascertainable with reasonable certainty as of the date of the decedent's death and decedent had already entered into a settlement with the state as to the amount of capital gain tax liability). 

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