Estate of Hall v. Commissioner
United States Tax Court
Decedent's will established a split-interest charitable remainder trust which failed to comply with the form requirements for deduction prescribed in sec. 2055(e)(2)(A), I.R.C. 1954. Petitioner claims that the trust was posthumously amended in a "qualified reformation" within the meaning of sec. 2055(e)(3), I.R.C. 1954. Held, no judicial proceeding was commenced to change the trust's remainder interests into deductible interests within the deadline set forth in sec.…
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Decedent's will established a split-interest charitable remainder trust which failed to comply with the form requirements for deduction prescribed in sec. 2055(e)(2)(A), I.R.C. 1954. Petitioner claims that the trust was posthumously amended in a "qualified reformation" within the meaning of sec. 2055(e)(3), I.R.C. 1954. Held, no judicial proceeding was commenced to change the trust's remainder interests into deductible interests within the deadline set forth in sec. 2055(e)(3)(C)(iii), I.R.C. 1954, with the result that there was no "qualified reformation" within the meaning of sec.…
1Opinion of the Court
Estate of Zella Hall, Deceased, Andrew Boyko, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Hall v. Commissioner
Docket No. 12751-87
United States Tax Court
93 T.C. 745; 1989 U.S. Tax Ct. LEXIS 156; 93 T.C. No. 60;
December 26, 1989December 26, 1989, Filed
Decision will be entered under Rule 155.
Decedent's will established a split-interest charitable remainder trust which failed to comply with the form requirements for deduction prescribed in sec. 2055(e)(2)(A), I.R.C. 1954. Petitioner claims that the trust was posthumously amended in a "qualified reformation"…
2Cases cited7 opinions
- Estate of Edgar v. CommissionerUnited States Tax Court · 1980
- First National Bank v. United StatesUnited States Court of Claims · 1978
- Shriners Hospitals for Crippled Children, as Transferee and Successor in Interest to the Estate of Ernest C. Hudson v. The United StatesCourt of Appeals for the Federal Circuit · 1988
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
- Oxford Orphanage, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1985
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