The following excerpt is from Leopold v. U.S., 510 F.2d 617 (9th Cir. 1975):
Section 2053(a)(3) does authorize deductions from the gross estate for amounts paid to satisfy 'claims against the estate.' However, subsection (c)(1)(A) further provides that deductions 'shall, when founded on a promise or agreement, be limited to the extent that they were contracted bona fide and for an adequate and full consideration in money or money's worth * * *.' One purpose of this limitation is to prevent testators from depleting their estates by transforming bequests to the natural objects of their bounty into deductible claims. United States v. Stapf, 375 U.S. 118, 130--133, 84 S.Ct. 248, 11 L.Ed.2d 195 (1963).
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