Estate of McAllister v. Commissioner
United States Tax Court
The decedent, a nonresident alien, provided in his will that 25 percent of the income of his residuary estate be paid to a Canadian foundation; said income to be used for the benefit of Canadian students attending the Michigan College of Mining and Technology. The bequest was predicated upon the condition that the college establish a foundation which was tax exempt under Canadian law.
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The decedent, a nonresident alien, provided in his will that 25 percent of the income of his residuary estate be paid to a Canadian foundation; said income to be used for the benefit of Canadian students attending the Michigan College of Mining and Technology. The bequest was predicated upon the condition that the college establish a foundation which was tax exempt under Canadian law. Said tax-exempt foundation was, in fact, established and the specified income was paid to Canadian students in the form of checks which were mailed directly to Michigan College where, upon arrival, the students…
1Opinion of the Court
Estate of John Edgar McAllister, Samuel Lewis McAllister and Merrill Des Brisay, Executors, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of McAllister v. Commissioner
Docket No. 5444-67
United States Tax Court
54 T.C. 1407; 1970 U.S. Tax Ct. LEXIS 103;
June 25, 1970, Filed
Decision will be entered under Rule 50.
The decedent, a nonresident alien, provided in his will that 25 percent of the income of his residuary estate be paid to a Canadian foundation; said income to be used for the benefit of Canadian students attending the Michigan College of Mining and Technology. The…
2Cases cited8 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Estate of Russell Harrison Varian, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Morey v. RiddellDistrict Court, S.D. California · 1962
- Varian v. CommissionerUnited States Tax Court · 1966
- Buckwalter v. CommissionerUnited States Tax Court · 1966
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