Hallett v. Commissioner
United States Board of Tax Appeals
The decedent bequeathed the residue of his estate to trustees for charitable purposes, with the provision, however, that the trustees "shall make payments for the relief and support" of certain relatives "who, through misfortune, may be in need of such relief, and support."
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The decedent bequeathed the residue of his estate to trustees for charitable purposes, with the provision, however, that the trustees "shall make payments for the relief and support" of certain relatives "who, through misfortune, may be in need of such relief, and support." Held, that the value of the residuary estate at the time of decedent's death, without diminution on account of the contingent interests of the relatives, is deductible in computing the net taxable estate for estate tax purposes.
1Opinion of the Court
OPINION.
Smith :
This proceeding involves a deficiency in estate tax of the estate of Herbert B. Moulton in the amount of $9,303.06. The only question for our determination is what amount of the residue of tbe decedent’s estate is deductible from the gross estate as a bequest to charity.
The decedent died a resident of Lisbon, Grafton County, New Hampshire, December 25, 1928, leaving a last will and testament by which he disposed of his entire estate, valued by the respondent at $961,422.55. After making numerous specific bequests to individuals and to charity the decedent bequeathed the residue…
2Cases cited6 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Edwards v. SlocumSupreme Court of the United States · 1924
- Humes v. United StatesSupreme Court of the United States · 1928
- Simpson v. United StatesSupreme Court of the United States · 1920
- United States v. Farr's Ex'rDistrict Court, E.D. Pennsylvania · 1912
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3Cited by1 opinion
- Hallett v. CommissionerUnited States Board of Tax Appeals · 1933