Oxford Orphanage, Inc. v. United States

BUTZNER, Senior Circuit Judge:

W. Eugene Johnston, executor of the estate of Howard S. Hunt and cotrustee of Hunt’s testamentary trust, and the charitable beneficiaries of the trust, Oxford Orphanage and Shriners Hospitals for Crippled Children, appeal from a judgment awarding the government interest on the amount of estate tax that would have been due but for amendment of Hunt’s will after he died. The amendment converted his bequests of charitable remainders into qualifying gifts to charity pursuant to the Internal Revenue Code § 2055(e)(3). On cross appeal the government contends that the…