Joyce Ingalls is the daughter of the late Fred Ingalls, who died Aug 15,2010. One of the items included in his gross estate was a traditional(regular/non-Roth) IRA valued at several million dollars. Mr.Ingalls's estate will ow taxes, but no estate taxes had been paid by March 1.2011, the date Joyce filed her 2010 was a $50,000distribution from her father's IRA. After talking with a friend , she wonders whether a Sec.691(c) deduction was available on her 2010 return, and she has contracted you to resolve this issue. write a memo in which you adrress whether Joyce is entitled to claim a Sec.681(c) deduction for income in respect of a decedent (IRD) she collected, given that no estate tac 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)
FSA 200011023