Estate of Clopton v. Commissioner
United States Tax Court
An inter vivos trust, includable in P, the grantor's estate, distributed funds to an educational organization which had had its tax-exempt status revoked. The donee organization had been deleted from the IRS Cumulative List prior to the date of the distribution, but revocation of its tax-exempt status was never published in the Internal Revenue Bulletin. Held, P is not entitled to a sec. 2055(a) estate tax deduction.
Read the full summary
An inter vivos trust, includable in P, the grantor's estate, distributed funds to an educational organization which had had its tax-exempt status revoked. The donee organization had been deleted from the IRS Cumulative List prior to the date of the distribution, but revocation of its tax-exempt status was never published in the Internal Revenue Bulletin. Held, P is not entitled to a sec. 2055(a) estate tax deduction. Held, further, the trustees' lack of personal knowledge of the deletion is immaterial.
1Opinion of the Court
Estate of Sally H. Clopton, Deceased, George M. Modlin, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Clopton v. Commissioner
Docket No. 2047-82
United States Tax Court
93 T.C. 275; 1989 U.S. Tax Ct. LEXIS 121; 93 T.C. No. 25;
August 29, 1989August 29, 1989, Filed
Decision will be entered under Rule 155.
An inter vivos trust, includable in P, the grantor's estate, distributed funds to an educational organization which had had its tax-exempt status revoked. The donee organization had been deleted from the IRS Cumulative List prior to the date of the distribution, but…
2Cases cited15 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Beatty v. . Guggenheim Exploration Co.New York Court of Appeals · 1919
- United States v. CalderonSupreme Court of the United States · 1954
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
10 more not listed; retrieve them via the Exa API.