[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.642(g)-2]

[Page 48]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.642(g)-2  Deductions included.

    It is not required that the total deductions, or the total amount of 
any deduction, to which section 642(g) is applicable be treated in the 
same way. One deduction or portion of a deduction may be allowed for 
income tax purposes if the appropriate statement is filed, while another 
deduction or portion is allowed for estate tax purposes. Section 642(g) 
has no application to deductions for taxes, interest, business expenses, 
and other items accrued at the date of a decedent's death so that they 
are allowable as a deduction under section 2053(a)(3) for estate tax 
purposes as claims against the estate, and are also allowable under 
section 691(b) as deductions in respect of a decedent for income tax 
purposes. However, section 642(g) is applicable to deductions for 
interest, business expenses, and other items not accrued at the date of 
the decedent's death so that they are allowable as deductions for estate 
tax purposes only as administration expenses under section 2053(a)(2). 
Although deductible under section 2053(a)(3) in determining the value of 
the taxable estate of a decedent, medical, dental, etc., expenses of a 
decedent which are paid by the estate of the decedent are not deductible 
in computing the taxable income of the estate. See section 213(d) and 
the regulations thereunder for rules relating to the deductibility of 
such expenses in computing the taxable income of the decedent.