Before her death, Lucy entered into the following transactions. Discuss the estate and income tax ramifications of each of these transactions.

A. Lucy borrowed $600,000 from her brother, Irwin, so that Lucy could start a business. The loan was on open account, and no interest or due date was provided for. Under applicable state law, collection on the loan was barred by the statute of limitations before Lucy died. Because the family thought that Irwin should recover his funds, the executor of the estate paid him $600,000.

B. Lucy Promised her sister, Ida, a bequest of $500,000 if IDA would move in with her and care fore her during illness (which eventually proved to be terminal). Lucy never kept her promise, her will was silent on any bequest to IDA. After Lucy's death, Ida sued the estate and eventually recovered $600,000 for breach of contract.

Please use some of these sources ( section 2053; Reg section 20.2053-4(d)(4) and (7); Estate of Allie W Pittard, 69 T.C. 391; Joseph F. Kenefic, 36, TCM 1226, T.C. Memo 1977-310; and HIbernia Bank v. U.S., 78-2 USTC paragraph 13,261, 42 AFTR 2d 78-6510,581 F.2d 741) to provide a memo to file regarding the estate and income tax ramifications of each of these transactions.