Legal Opinion

Estate of Sternberger v. Commissioner

United States Tax Court

Decided July 31, 1952No. Docket No. 31348Published

1. A contingent remainder of a trust and the residue of a will went to charity, and a charitable deduction was claimed on the estate tax return. The will disposes of decedent's residuary estate by providing that the same be held in trust during the joint lives of decedent's wife and his daughter and the life of the survivor of them. Upon the death of the survivor the principal is payable to the descendants then living of the daughter.

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1. A contingent remainder of a trust and the residue of a will went to charity, and a charitable deduction was claimed on the estate tax return. The will disposes of decedent's residuary estate by providing that the same be held in trust during the joint lives of decedent's wife and his daughter and the life of the survivor of them. Upon the death of the survivor the principal is payable to the descendants then living of the daughter. In the event there are no descendants of the daughter the principal is payable one-half to certain collateral relatives of the decedent then living and one-half…

1Opinion of the Court

Estate of Louis Sternberger, the Chase National Bank of the City of New York, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Estate of Sternberger v. Commissioner

Docket No. 31348

United States Tax Court

18 T.C. 836; 1952 U.S. Tax Ct. LEXIS 128;

July 31, 1952, Promulgated

Decision will be entered under Rule 50.

1. A contingent remainder of a trust and the residue of a will went to charity, and a charitable deduction was claimed on the estate tax return. The will disposes of decedent's residuary estate by providing that the same be held in trust during the joint lives of…

2Cases cited8 opinions

  1. Humes v. United StatesSupreme Court of the United States · 1928
  2. Robinette v. HelveringSupreme Court of the United States · 1943
  3. Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
  4. Estate of Maresi v. CommissionerUnited States Tax Court · 1946
  5. Adams v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1940

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