Estate of Christiansen v. Comm'r
United States Tax Court
H was the only legatee of her mother's will. H disclaimed the portion of the gross estate that had a fair market value of more than $ 6,350,000. The will provided that any disclaimed portion would pass in part to a charitable foundation and in part to a charitable trust that would pay an annuity to the foundation. H did not disclaim a contingent remainder in the property passing to the charitable trust.
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H was the only legatee of her mother's will. H disclaimed the portion of the gross estate that had a fair market value of more than $ 6,350,000. The will provided that any disclaimed portion would pass in part to a charitable foundation and in part to a charitable trust that would pay an annuity to the foundation. H did not disclaim a contingent remainder in the property passing to the charitable trust. On the estate's tax return, it deducted as charitable contributions the disclaimed property passing to the foundation and -- to the extent of the present value of the annuity interest -- the…
1Opinion of the Court
ESTATE OF HELEN CHRISTIANSEN, DECEASED, CHRISTINE CHRISTIANSEN HAMILTON, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Christiansen v. Comm'r
No. 15190-05
United States Tax Court
130 T.C. 1; 2008 U.S. Tax Ct. LEXIS 1; 130 T.C. No. 1;
January 24, 2008, Filed
Decision was entered under U.S. Tax Ct. R. 155.
H was the only legatee of her mother's will. H disclaimed the portion of the gross estate that had a fair market value of more than $ 6,350,000. The will provided that any disclaimed portion would pass in part to a charitable foundation and in part to…
Also in this document: Concurring in part, dissenting in part · Swift; Concurring in part, dissenting in part · Kroupa.
2Cases cited19 opinions
- Commissioner v. TellierSupreme Court of the United States · 1966
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Ward v. CommissionerUnited States Tax Court · 1986
- Commissioner of Internal Revenue v. ProcterCourt of Appeals for the Fourth Circuit · 1944
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