Legal Opinion

Gray v. Commissioner

United States Tax Court

Decided June 11, 1943No. Docket No. 109237Published

The decedent bequeathed certain remainder interests to the Presbyterian Hospital in the City of New York, a corporation organized and operated exclusively for charitable purposes. The bequests were to be added to, or used to create, a fund the net income of which is to be used to provide special nurses and special nursing care for graduate nurses who are patients of the hospital.

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The decedent bequeathed certain remainder interests to the Presbyterian Hospital in the City of New York, a corporation organized and operated exclusively for charitable purposes. The bequests were to be added to, or used to create, a fund the net income of which is to be used to provide special nurses and special nursing care for graduate nurses who are patients of the hospital. Held, the value of the remainder interests is deductible from the value of the gross estate as a charitable bequest within the purview of section 303 (a) (3) of the Revenue Act of 1926, as amended by section 807 of…

1Opinion of the Court

Estate of Carolyn E. Gray, Deceased, the New York Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Gray v. Commissioner

Docket No. 109237

United States Tax Court

2 T.C. 97; 1943 U.S. Tax Ct. LEXIS 142;

June 11, 1943, Promulgated

Decision will be entered for the petitioner.

The decedent bequeathed certain remainder interests to the Presbyterian Hospital in the City of New York, a corporation organized and operated exclusively for charitable purposes. The bequests were to be added to, or used to create, a fund the net income of which is to be used to provide special…

2Cases cited11 opinions

  1. Harrison v. Northern Trust Co.Supreme Court of the United States · 1943
  2. Trustees of the Sailors' Snug Harbor v. CarmodyNew York Court of Appeals · 1914
  3. Manley v. FiskeAppellate Division of the Supreme Court of the State of New York · 1910
  4. Starr v. SelleckAppellate Division of the Supreme Court of the State of New York · 1911
  5. In re the Judicial Settlement of the Account of Proceedings of MillerAppellate Division of the Supreme Court of the State of New York · 1912

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