offering was a “reasonable and necessary” and, therefore, deductible cost of Mrs. Black’s estate. Respondent argues that the reimbursement was not “necessary” within the meaning of section 20.2053-3(a), Estate Tax Regs., because the Erie stock belonged to Black LP, not Mrs. Black’s estate, and that Black LP sold the stock. To the extent the secondary offering of Erie stock generated funds needed and used to discharge debts of Mrs. Black’s estate, Black LP’s obligation to reimburse Erie for costs associated with that offering was related to and occasioned by Mrs. Black’s death, and, for that reason, the reimbursement might be deductible by her estate under section 2053. Accord sec. 20.2053-8(d), Example (2), Estate Tax Regs.; see Burrow Trust v. Commissioner, 39 T.C. 1080, 1089 (1963) (<HOLDING>), affd. 333 F.2d 66 (10th Cir. 1964). Moreover,
holding that trustees fiduciary duty exists independent of any clause in trust agreement holding an internal error that caused the movant to receive the trustees notice of motion twentysix days after the court heard the trustees motion  may have constituted excusable neglect had the movant made a prompt motion for reconsideration and pointing out it is the movants actions after he became aware of the existence of the trustees motion  that reaches the level of willfulness holding that trustees act of conveying entire corpus terminated the trust holding that the csu board of trustees and individual trustees sued in their official capacity are a political arm of the state and as such are immune from suit holding that where a revocable inter vivos trust paid its own trustees fees the settlors estate could nonetheless deduct those fees under section 2053 because the trustees services were primarily occasioned by the death of the decedent