On Fiduciary Tax Returns will Distribution Deductions be allowed in these circumstances?
Client dies unmarried and without children, and with a 401K with $600,000 in it. The 401K has no named beneficiary. The 401K will be paid to client's estate all at once, no stretch is allowed. The beneficiary of the client's estate is client's mother. However just a few months after client's death, mother dies. So, client's estate will pay the $600,000 to the estate of client's mother which will then distribute it to mother's other 3 children. Will the client's estate income tax return be entitled to a distribution deduction for the payment of the $6000,000 to mother's estate, and then will mother's estate income tax return be entitled to a distribution deduction when the $600,000 is paid to her 3 children so that the $600,000 can be taxed at the beneficiaries' level which will be a much lower rate?
