From what you say, there is no possible roll over from trustee to trustee. A lump sum was made and sitting in cash.
As to whom pays the tax, they depends in large part of whether any distributions are made to the beneficiaries. If no distributions are made, then there is no distributable income deduction. Unless the estate in its taxable year has other deductions to drop taxable income to zero or less, the estate will pay taxes.
However, if distributions are made to beneficiaries, then a computation is made to determine distributive income and what remains in the estate to be taxed.
Not an easy question to answer as there are many variables.
**Disclaimer: Effort has been made to offer correct information; but due to the discussion forum limitations, the poster disclaims any legal responsibility for the accuracy of the poster's response**
