Gray v. Commissioner
United States Tax Court
The decedent bequeathed certain remainder interests to the Presbyterian Hospital in the City of New York, a corporation organized and operated exclusively for charitable purposes. The bequests were to be added to, or used to create, a fund the net income of which is to be used to provide special nurses and special nursing care for graduate nurses who are patients of the hospital.
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The decedent bequeathed certain remainder interests to the Presbyterian Hospital in the City of New York, a corporation organized and operated exclusively for charitable purposes. The bequests were to be added to, or used to create, a fund the net income of which is to be used to provide special nurses and special nursing care for graduate nurses who are patients of the hospital. Held, the value of the remainder interests is deductible from the value of the gross estate as a charitable bequest within the purview of section 303 (a) (3) of the Revenue Act of 1926, as amended by section 807 of…
1Opinion of the Court
OPINION.
Harron, Judge:
The facts have been stipulated, the material part being as follows:
The petitioner, the New York Trust Company, 100 Broadway, New York, New York, is the duly appointed, qualified and acting Executor of the last will and testament of Carolyn E. Gray, deceased, who died a resident of the City, County and State of New York, on December 29,1938.
Said last will and testament of said decedent, * * * was duly admitted to probate by the Surrogate’s Court of New York County on February 23, 1939, at which time petitioner was appointed and duly qualified as Executor thereof.
Said last…
2Cases cited10 opinions
- Harrison v. Northern Trust Co.Supreme Court of the United States · 1943
- Trustees of the Sailors' Snug Harbor v. CarmodyNew York Court of Appeals · 1914
- Manley v. FiskeAppellate Division of the Supreme Court of the State of New York · 1910
- Starr v. SelleckAppellate Division of the Supreme Court of the State of New York · 1911
- In re the Judicial Settlement of the Account of Proceedings of MillerAppellate Division of the Supreme Court of the State of New York · 1912
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3Cited by4 opinions
- Davis v. CommissionerUnited States Tax Court · 1956
- Davis v. CommissionerUnited States Tax Court · 1956
- Estate of Wald v. CommissionerUnited States Tax Court · 1944
- Gray v. CommissionerUnited States Tax Court · 1943