James P. Flanagan, Administrator of the Estate of Frank Parkes, Deceased v. United States

LOGAN, Circuit Judge.

James P. Flanagan, as administrator of the estate of Frank Parkes, appeals from the district court judgment denying his claim for a refund of federal estate taxes. He alleges that the Internal Revenue Service (IRS) wrongly refused to allow the estate a charitable deduction for property transferred to a charitable corporation. The sole issue on appeal is whether the IRS properly disallowed the deduction because the bequest was in the nature of a split interest transfer that did not qualify for the charitable deduction under any of the provisions of the Internal Revenue…