Joyce Ingalls is the daughter of the late Fred Ingalls, who died August 15, 2014. One of the items included in his gross estate was a traditional (non-Roth) IRA valued at several million dollars. Mr. Ingalls’s estate will owe estate taxes, but none had been paid by March 1, 2015, the date Joyce filed her 2014 individual income tax return, which she prepared herself. Included in her gross income for 2014 was a $50,000 distribution from her father’s IRA. After talking with a friend, she wonders whether a Sec. 691(c) deduction was available on her 2014 return, and she has contacted you to resolve this issue. Write a memo in which you address whether Joyce is entitled to claim a Sec. 691(c) deduction for income in respect of a decedent (IRD) she collected, given that no estate tax has yet been paid on the IRD or any other inclusion in her father’s gross estate. Also address in a conceptual manner how the deduction, assuming it is available, is calculated. At a minimum you should consult the following sources: • IRC Sec. 691(c)