For the first five months of its existence (August through December 2020), the Estate of Amy Ennis had gross income (net of expenses) of $7,000 per month. For January through July 2021, the executor estimates that the estate will have gross income (net of expenses) totaling $5,000. The estate’s sole beneficiary is Amy’s uncle, Joe, an unmarried, calendar year taxpayer. Joe incurred a large NOL from his sole proprietorship years ago, and $34,000 of the pre-2018 NOL carryover remains but expires at the end of 2020. During 2020, Joe’s only income was $10,000 from part-time employment. What tax issues should the executor of Amy’s estate consider with respect to distributions of the estate’s income?