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The tax court correctly concluded that it was not required to allocate the burden of proof in this case. Even if there was error with respect to burden allocation, any such error was harmless because a preponderance of the evidence supported that the IRS Commissioner had determined the deficiencies at issue correctly. The estate’s deduction of loan interest was not proper as an administrative expense under I.R.C. § 2053(a)(2) because the estate had sufficient assets to pay a tax liability instead of obtaining a loan. It would not have violated fiduciary duties if a pro rata distribution had been made to enable the estate to pay its tax liability. The tax court did not err in determining fair market value of the trust’s interests in an LLC and did not clearly err in assuming that interests would be redeemed pursuant to agreements that had been signed. The tax court’s judgment was affirmed.