I am trying to figure out this problem:

Before her death in 2009, Lucy entered into the following transactions.

In 2000, 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. Discuss the estate and income tax ramifications.