Legal Opinion
National Bank of Commerce in Memphis and John S. Montedonico, Co-Executors of the Estate of Elizabeth G. Frank, Deceased v. United States
Court of Appeals for the Sixth Circuit
Decided February 16, 1970No. 19305_1PublishedCited by 9 opinions
1Opinion of the Court
McCREE, Circuit Judge.
Elizabeth G. Frank died testate in 1963 and left the residuary of her estate, approximately $1,000,000, to four trusts. The income from each of these trusts was to be paid to specified individuals for life. Neither the beneficiaries nor the trustees were given any right to invade the corpus. On the death of each life tenant, the corpus of his trust was to be paid over to specified charities.
When Miss Frank’s executors prepared the federal estate tax return, they sought to deduct from the gross estate the value of the bequests to charity as permitted by § 2055 of the…
2Cases cited3 opinions
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- Gutman v. CommissionerUnited States Board of Tax Appeals · 1940
- MacKinac Island Carriage Tours, Inc., a Michigan Corporation v. Commissioner of Internal Revenue, MacKinac Island Carriage Tours, Inc., a Michigan Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
3Cited by9 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Fort Worth National Bank v. United StatesDistrict Court, N.D. Texas · 1975
- RERI Holdings I, LLC v. Comm'rUnited States Tax Court · 2014
- Edgar v. CommissionerUnited States Tax Court · 1971
- Estate of Bachman v. CommissionerUnited States Tax Court · 1975
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