Estate of Jaecker v. Commissioner
United States Tax Court
In his last will and testament, the decedent created three trusts. Each of the trusts established a reserved life estate, one of the trusts also established two secondary life estates, and each of the trusts provided for ultimate remainders to certain charities.
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In his last will and testament, the decedent created three trusts. Each of the trusts established a reserved life estate, one of the trusts also established two secondary life estates, and each of the trusts provided for ultimate remainders to certain charities. The trustees of each of the trusts were given broad administrative and investment powers without any restrictions to which fiduciaries are ordinarily subject, except the duty to act in good faith and with reasonable care. The life beneficiary of each of the trusts disclaimed his rights under the trusts to have the administrative and…
1Opinion of the Court
Quealy, Judge:
The respondent determined a deficiency in the estate tax dne from the Estate of Harry C. Jaecker, deceased, in the amount of $2,150,208.62. Petitioners claim an overpayment of estate tax in the amount of $70,265.50. The sole issue for determination is whether the remainder interests in three trusts established by the will of the decedent qualified for a charitalble deduction pursuant to section 20551 where the trustees of each of the respective trusts were vested with broad discretionary investment and management powers.2
FINDINGS OP PACT
Some of the facts have been stipulated.…
2Cases cited16 opinions
- Child Labor Tax CaseSupreme Court of the United States · 1922
- Estate of Lillie MacMunn Stewart, Deceased, W. Alan Henderson v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1971
- Estate of Stewart v. CommissionerUnited States Tax Court · 1969
- Schoonmaker v. CommissionerUnited States Tax Court · 1946
- MacAulay v. CommissionerUnited States Tax Court · 1944
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3Cited by3 opinions
- Estate of Ryan v. CommissionerUnited States Tax Court · 1974
- Estate of Jaecker v. CommissionerUnited States Tax Court · 1972
- Estate of Ryan v. CommissionerUnited States Tax Court · 1974