Before her death, Lucy entered into the following transactions. 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. Lucy promised her sister, Ida, a bequest of $500,000 if Ida would move in with her and care for her during an illness (which eventually proved to be terminal). Lucy never kept her promise; her will was silent on any bequest to Ida. After Lucys death, Ida sued the estate and eventually recovered $600,000 for breach of contract. Partial list of research aids: 2053. Reg. 20.20534(d)(4) and (7). Estate of Allie W. Pittard, 69 T.C. 391 (1977). Joseph F. Kenefic, 36 TCM 1226, T.C.Memo. 1977310. Hibernia Bank v. U.S., 782 USTC 13,261, 42 AFTR 2d 786510, 581 F.2d 741 (CA9, 1978).

Prepare a Tax File memo for Bill Jones, Executor, of the Estate, addressing each transaction. Prepare a Client letter for Bill Jones with your conclusions.