There is also this on the subject of a deduction by the estate.
https://www.thetaxadviser.com/issues/2023/apr/10-estate-and-income-tax-questions.html
Despite case law supporting possible deductions, IRS Chief Counsel Memorandum 1998-012 explains that such a deduction is allowed only when the property has been converted to an income-producing property. The memorandum is not authoritative; however, it does provide insight into the IRS’s position and highlights an area of potential scrutiny.
