Legal Opinion

Estate of Leach v. Commissioner

United States Tax Court

Decided June 14, 1984No. Docket Nos. 2243-81, 2244-81Published

Prior to her death, decedent transferred common stock to three charitable remainder annuity trusts. Pursuant to the trust agreements, these trusts were to pay annuities to decedent for life and then to her husband, if he survived her. Upon the death of the last to die, remaining trust assets were to be distributed to charitable remaindermen designated in decedent's will.

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Prior to her death, decedent transferred common stock to three charitable remainder annuity trusts. Pursuant to the trust agreements, these trusts were to pay annuities to decedent for life and then to her husband, if he survived her. Upon the death of the last to die, remaining trust assets were to be distributed to charitable remaindermen designated in decedent's will. Decedent's will provided that an amount equal to 50 percent of her adjusted gross estate would be left to a marital trust, it being her stated desire to obtain the maximum marital deduction allowable. The will provided that…

1Opinion of the Court

Estate of Anne B. Leach, Deceased, George Howe Bailey, Jr., Administrator ad Litem, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Leach v. Commissioner

Docket Nos. 2243-81, 2244-81

United States Tax Court

82 T.C. 952; 1984 U.S. Tax Ct. LEXIS 57; 82 T.C. No. 72;

June 14, 1984, Filed

Decisions will be entered under Rule 155.

Prior to her death, decedent transferred common stock to three charitable remainder annuity trusts. Pursuant to the trust agreements, these trusts were to pay annuities to decedent for life and then to her husband, if he survived her. Upon the death of the…

2Cases cited24 opinions

  1. Riggs v. Del DragoSupreme Court of the United States · 1942
  2. Ingram v. United StatesSupreme Court of the United States · 1959
  3. Hagerty v. HagertySupreme Court of Florida · 1951
  4. Lederer v. Fidelity Trust Co.Supreme Court of the United States · 1925
  5. Wells v. MennSupreme Court of Florida · 1946

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