Mott v. United States
United States Court of Claims
1Opinion of the Court
Cowen, Chief Judge,
delivered tbe opinion óf the court1:*
■ ■ This tax case,^apparently one of -first impression, comes before tbe court -on tbe parties’ -cross-motions; for ¡suibmary judgment. Tbe. issue is whether ;an .estatqis. entitled, to a deduction from its ;gross income,pursuant .to1 Section '661(a) (2) of the Internal Revenue- Code of >1964:,1 -when it makes a distribution of corpus of an estate to a qualified charitable bene*130ficiary pursuant to a general pecuniary bequest. We have concluded that the claimed deduction is not available.
The pertinent facts, which have been stipulated, are…
2Cases cited5 opinions
- Irwin v. GavitSupreme Court of the United States · 1925
- Manufacturers Hanover Trust Company, as Trustee Under Indenture Dated November 15, 1927, Made by Henry H. Rogers, Deceased v. The United StatesUnited States Court of Claims · 1963
- Commissioner of Internal Revenue v. DeanCourt of Appeals for the Tenth Circuit · 1939
- Riggs National Bank v. United StatesUnited States Court of Claims · 1965
- Lonergan v. CommissionerUnited States Tax Court · 1946
3Cited by24 opinions
- Rollert Residuary Trust v. CommissionerUnited States Tax Court · 1983
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
- Du Pont Testamentary Trust v. CommissionerUnited States Tax Court · 1976
- Ellis First National Bank of Bradenton v. United StatesUnited States Court of Claims · 1977
- In Re Samoset AssociatesUnited States Bankruptcy Court, D. Maine · 1981
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