Joyce Ingalls is the daughter of the late Fred Ingalls, who died August 15 of the current year. 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 owe taxes, but no estate taxes had been paid by March 1 of next year, the date Joyce filed her current year individual income tax return, which she prepared. Included in her gross income for the current year was a $50,000 distribution from her father's IRA. After talking with a friend, she wonders whether a Sec. 691(c) deduction was available on her current year return, and she has contacted you to resolve this issue. Write a memo in which you address whether Joyce is entitled to claim a Sec. 691(c) deduction for income in respect of a decedent (IRD) she collected, given that no estate tax 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