Estate of La Meres v. Comm'r
United States Tax Court
Decedent devised the residue of his estate to a revocable trust, which he had established prior to death, for the benefit of both charitable and noncharitable beneficiaries. The bequest did not qualify for the estate tax deduction for bequests to charitable entities because it violated the prohibition against bequests of split interests in sec. 2055(e)(2), I.R.C.
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Decedent devised the residue of his estate to a revocable trust, which he had established prior to death, for the benefit of both charitable and noncharitable beneficiaries. The bequest did not qualify for the estate tax deduction for bequests to charitable entities because it violated the prohibition against bequests of split interests in sec. 2055(e)(2), I.R.C. After decedent's death, the trustees modified the dispositive provisions of the trust, effectively purging it of its split interest. The modification was not a "qualified reformation" under sec. 2055(e)(3), I.R.C.Held, where the only…
1Opinion of the Court
Estate of Eugene E. La Meres, Deceased, Kathy Koithan, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of La Meres v. Comm'r
Docket No. 6909-88
United States Tax Court
98 T.C. 294; 1992 U.S. Tax Ct. LEXIS 28; 98 T.C. No. 24;
March 23, 1992, Filed
Decision will be entered under Rule 155.
Decedent devised the residue of his estate to a revocable trust, which he had established prior to death, for the benefit of both charitable and noncharitable beneficiaries. The bequest did not qualify for the estate tax deduction for bequests to charitable entities because…
2Cases cited63 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- United States v. BoyleSupreme Court of the United States · 1985
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Crocker v. CommissionerUnited States Tax Court · 1989
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