Estate of Boeshore v. Commissioner
United States Tax Court
1. Decedent devised the residue of her estate to a charitable remainder trust. The trust provided for annual payments of a unitrust amount equal to 6 percent of the fair market value of the trust assets to be determined annually. For the life of decedent's surviving spouse, the unitrust amount was to be paid for private purposes.
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1. Decedent devised the residue of her estate to a charitable remainder trust. The trust provided for annual payments of a unitrust amount equal to 6 percent of the fair market value of the trust assets to be determined annually. For the life of decedent's surviving spouse, the unitrust amount was to be paid for private purposes. After the death of the surviving spouse and for the remainder of the unitrust term (measured by the last to die of three surviving descendants), the unitrust amount was to be paid for charitable purposes and for private purposes in the respective percentages of 42…
1Opinion of the Court
OPINION
Fay, Judge:
Respondent determined a deficiency of $101,358.53 in the Federal estate tax of the Estate of Minnie L. Boeshore. After concessions, the issues are (1) whether a deduction is allowable for the present value of a certain charitable unitrust interest created by a testamentary trust, and (2) the correct actuarial computation of the present value of a charitable remainder interest created by a separate inter vivos trust.
All the facts have been stipulated and are found accordingly.
Petitioners Lincoln National Bank & Trust Co. of Fort Wayne and Melvin V. Ehrman are the executors of…
2Cases cited13 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
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- American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
- McMurtry v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Coady v. CommissionerUnited States Tax Court · 1960
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