Estate of Burdick v. Commissioner
United States Tax Court
Decedent's will provided for a charitable remainder interest that did not qualify for an estate tax deduction under sec. 2055(e)(2)(A), I.R.C. 1954. The estate did not reform the charitable remainder interest under the relief provisions of sec. 2055(e)(3), I.R.C. 1954. Solely in an attempt to qualify the charitable bequest for an estate tax deduction, the executor paid $ 60,000 to the specified charitable organization in termination of the charitable remainder interest.
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Decedent's will provided for a charitable remainder interest that did not qualify for an estate tax deduction under sec. 2055(e)(2)(A), I.R.C. 1954. The estate did not reform the charitable remainder interest under the relief provisions of sec. 2055(e)(3), I.R.C. 1954. Solely in an attempt to qualify the charitable bequest for an estate tax deduction, the executor paid $ 60,000 to the specified charitable organization in termination of the charitable remainder interest. Held: Where the only reason for termination or modification of an otherwise nonqualifying split-interest charitable bequest…
1Opinion of the Court
Estate of Perrin V. Burdick, Deceased, Thomas A. Burdick, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Burdick v. Commissioner
Docket No. 34058-87
United States Tax Court
96 T.C. 168; 1991 U.S. Tax Ct. LEXIS 8; 96 T.C. No. 8;
February 4, 1991, Filed
Decision will be entered under Rule 155.
Decedent's will provided for a charitable remainder interest that did not qualify for an estate tax deduction under sec. 2055(e)(2)(A), I.R.C. 1954. The estate did not reform the charitable remainder interest under the relief provisions of sec. 2055(e)(3), I.R.C. 1954. Solely in…
2Cases cited10 opinions
- Commissioner v. Estate of SternbergerSupreme Court of the United States · 1955
- First National Bank of Fayetteville, Arkansas, of the Estate of Jesse W. Cannon, Deceased v. United StatesCourt of Appeals for the First Circuit · 1984
- William J. Oetting, of the Estate of Irma H. Dunmeyer, Deceased v. United StatesCourt of Appeals for the Eighth Circuit · 1983
- James P. Flanagan, Administrator of the Estate of Frank Parkes, Deceased v. United StatesCourt of Appeals for the Tenth Circuit · 1987
- Estate of Edgar v. CommissionerUnited States Tax Court · 1980
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