Estate of Stanley M. Carpenter, Deceased William R. Thomas, Administrator v. Commissioner of the Internal Revenue Service

Affirmed by published opinion. Judge MOTZ wrote the opinion, in which Judge WIDENER and Judge MICHAEL joined.

OPINION

MOTZ, Circuit Judge:

This appeal involves the widowed beneficiary of a trust created pursuant to her husband’s will, who accepted certain funds as part of a settlement agreement after a dispute arose over the terms of the trust. The tax court found that because the widow’s interest under the trust was a life estate unaccompanied by a general power of appointment, the decedent’s estate was not entitled to a marital deduction for funds paid to the widow as part of the settlement.…