Britenstool v. Commissioner
United States Tax Court
1. Held, in computing the amount of a charitable deduction under section 2055, I.R.C. 1954, when there has been an election under section 642(g), I.R.C. 1954, to deduct administration expenses in computing the income of the estate rather than in computing the taxable estate, and when the income beneficiary is required under State law to reimburse a charity for a reduction in a charitable contribution resulting from such election, the charitable contribution includes the…
Read the full summary
1. Held, in computing the amount of a charitable deduction under section 2055, I.R.C. 1954, when there has been an election under section 642(g), I.R.C. 1954, to deduct administration expenses in computing the income of the estate rather than in computing the taxable estate, and when the income beneficiary is required under State law to reimburse a charity for a reduction in a charitable contribution resulting from such election, the charitable contribution includes the amount of such reimbursement. 2. Held, a payment by petitioner in satisfaction of a claim against the estate was approved by…
1Opinion of the Court
Estate of Harry Britenstool, Deceased, by Manufacturers Hanover Trust Company (Successor by Merger to the Hanover Bank), as Sole Surviving Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Britenstool v. Commissioner
Docket No. 4170-64
United States Tax Court
46 T.C. 711; 1966 U.S. Tax Ct. LEXIS 47;
September 2, 1966, Filed
Decision will be entered under Rule 50.
1. Held, in computing the amount of a charitable deduction under section 2055, I.R.C. 1954, when there has been an election under section 642(g), I.R.C. 1954, to deduct administration expenses in computing the income of…
2Cases cited19 opinions
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- Baird v. CommissionerUnited States Tax Court · 1955
- Will Flitcroft and Agnes D. Flitcroft v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Estate of Edward H. Luehrmann, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
14 more not listed; retrieve them via the Exa API.