Louis Brandeis, Woerishoffer v. United States…
“ The reason why no further or complete distribution of the residuary estate was made by the executors prior to July 1, 1902, was that they anticipated that the estate would be liable for payment of a New York estate transfer tax and the federal inheritance tax, for attorneys' fees, and other expenses of administration, and that the exact amount of the residuary estate left for distribution could therefore not be definitely determined prior to July 1, 1902. ”
