Unfortunately, no. The fees were payable by the estate and deductible only by the estate. If there had been a federal estate tax, you would have been entitled to a write-off for the federal estate tax with respect to the IRA. This is because the IRA is income in respect of a decedent (income earned by the person before death that is taxed to someone else after the person’s death). However, since there was no estate tax, you don’t get any deduction.
A business loss that exceeds current income may be carried back against income of prior years and carried forward as a deduction from future income until eliminated.