In Re the Estate of Pickrell

The trial court and our majority have reached the correct result, and, while I do not disagree with the general statements of law of the majority opinion, I differ from the majority’s reasoning in reaching the same result.

The second article of the will provides:

“[A]ll Federal estate taxes . . . and all inheritance . . . taxes . . ., whether or not attributed to properties subject to probate administration,. . . and all expenses of administration of my estate, shall be paid out of the residue of my probate estate.

My executors shall not be reimbursed for, nor collect, any part of such taxes or…