Legal Opinion

Carlson v. Commissioner

United States Tax Court

Decided November 24, 1953No. Docket No. 39615Published

Estate Tax -- Deduction -- Charitable Bequest -- Exclusively -- Sec. 812 (d), I. R. C. -- A residuary bequest, after a life estate of measurable value, gives rise to a deduction under section 812 (d) where left to trustees as a "Retirement and/or Welfare Fund" for employees of a corporation.

1Opinion of the Court

Estate of Leonard O. Carlson, N. A. Carlson, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Carlson v. Commissioner

Docket No. 39615

United States Tax Court

21 T.C. 291; 1953 U.S. Tax Ct. LEXIS 21;

November 24, 1953, Promulgated

Decision will be entered under Rule 50.

Estate Tax -- Deduction -- Charitable Bequest -- Exclusively -- Sec. 812 (d), I. R. C. -- A residuary bequest, after a life estate of measurable value, gives rise to a deduction under section 812 (d) where left to trustees as a "Retirement and/or Welfare Fund" for employees of a corporation.

Enoch C. Filer, Esq.,…

2Cases cited10 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Bok v. McCaughnCourt of Appeals for the Third Circuit · 1930
  3. Eagan v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1930
  4. Gimbel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931
  5. Harrison v. Barker Annuity FundCourt of Appeals for the Seventh Circuit · 1937

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