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Under the terms of the guarantee, the Service reasoned, the taxpayer's estate would become liable for the loan guarantee; any property that could be used to satisfy that guarantee could not qualify for the marital deduction, since such property was at least potentially "encumbered" with the guarantee. Since many parents guarantee their children's loans, this ruling has caused great concern.

In Letter Ruling 9409018, the IRS reversed its 1990 ruling and stated that the marital deduction should not be reduced by the entire unpaid balance of the guaranteed loans, unless at the time of the taxpayer's death it appeared that a default was imminent, performance under the guarantee was likely and any subrogation rights were worthless.

If it was determined that the marital deduction would have to be reduced as a result of default being imminent, the estate should be able to take a deduction for payment of the guaranteed obligation.

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Holly is on an airliner returning from a business trip and John is awaiting her arrival. Meanwhile a company of former special forces members, led by former Colonel Stuart (William Sadler), execute their plot to take over the control of the airport's electronic systems. A company of soldiers, led by Major Grant (John Amos), eventually arrive on the scene ostensibly to deal with Stuart and what's left of his company.

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