Legal Opinion

Christy v. Commissioner

United States Tax Court

Decided April 23, 1947No. Docket No. 9223Published

Estate Tax -- Deduction -- Charitable Bequest. -- A residuary bequest to charity is not deductible where the principal of the trust can be used for the comfort and support of the life tenants if the income is not sufficient for that purpose, even though that income with separate income of the life tenants would be sufficient, since under the law of Pennsylvania the trust principal can be exhausted under such circumstances before the life beneficiary need resort to her own…

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Estate Tax -- Deduction -- Charitable Bequest. -- A residuary bequest to charity is not deductible where the principal of the trust can be used for the comfort and support of the life tenants if the income is not sufficient for that purpose, even though that income with separate income of the life tenants would be sufficient, since under the law of Pennsylvania the trust principal can be exhausted under such circumstances before the life beneficiary need resort to her own income.

1Opinion of the Court

Estate of Bayard H. Christy, Deceased, Peoples-Pittsburgh Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Christy v. Commissioner

Docket No. 9223

United States Tax Court

8 T.C. 862; 1947 U.S. Tax Ct. LEXIS 221;

April 23, 1947, Promulgated

Decision will be entered under Rule 50.

Estate Tax -- Deduction -- Charitable Bequest. -- A residuary bequest to charity is not deductible where the principal of the trust can be used for the comfort and support of the life tenants if the income is not sufficient for that purpose, even though that income with separate income of…

2Cases cited4 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
  3. Christy v. CommissionerUnited States Tax Court · 1947
  4. Frederick M. Crane's EstateSupreme Court of Pennsylvania · 1896

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