Estate of Pfeifer v. Commissioner
United States Tax Court
Decedent Louis E. Pfeifer provided in his will for the creation of a trust in which his surviving spouse, Ella Pfeifer, was entitled to income for life and was given a testamentary power of appointment over the corpus. Ella Pfeifer, who was 85 years old at Louis' death, executed an affidavit in compliance with sec. 2055(b)(2), I.R.C. 1954, declaring her intention to exercise her testamentary power of appointment in favor of certain charitable organizations.
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Decedent Louis E. Pfeifer provided in his will for the creation of a trust in which his surviving spouse, Ella Pfeifer, was entitled to income for life and was given a testamentary power of appointment over the corpus. Ella Pfeifer, who was 85 years old at Louis' death, executed an affidavit in compliance with sec. 2055(b)(2), I.R.C. 1954, declaring her intention to exercise her testamentary power of appointment in favor of certain charitable organizations. Ella died in 1971 and in her will exercised her power as specified in her earlier affidavit. Held, Louis' estate is entitled to an estate…
1Opinion of the Court
OPINION
Featherston, Jvdge:
In these consolidated cases,2 respondent determined deficiencies in the estate taxes of the estate of Ella Pfeifer in the amount of $43,539.58 and the estate of Louis E. Pfeifer in the amount of $49,823.41. Certain issues having been disposed of by the parties, the issues remaining for decision are:(1) Whether the estate of Louis E. Pfeifer, from which decedent’s surviving spouse was given a life estate in certain property with a general testamentary power of appointment, is entitled to a charitable deduction under section 2055(b)(2)3 for the remainder interest to be…
2Cases cited3 opinions
- Miller v. CommissionerUnited States Tax Court · 1967
- Estate of Hugh Gordon Miller, Deceased, Allen Gordon Miller, Edwin Schroff and Helen T. Ives v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Estate of Edna Allen Miller, Deceased, Allen Gordon Miller and Erwin SchroffCourt of Appeals for the Third Circuit · 1968
- Miller v. CommissionerUnited States Tax Court · 1967
3Cited by10 opinions
- Estate of Flanigan v. CommissionerCourt of Appeals for the Eleventh Circuit · 1984
- Estate of Hoskins v. CommissionerUnited States Tax Court · 1978
- Estate of Aimee Magnus Flanigan, Deceased, Peter M. Flanigan, Personal Representative v. Commissioner, Internal Revenue, Estate of Horace C. Flanigan, Deceased, Peter M. Flanigan, Personal Representative v. Commissioner, Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Estate of Sorenson v. CommissionerUnited States Tax Court · 1979
- Estate of Reeves v. CommissionerUnited States Tax Court · 1993
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