Estate of Blackford v. Commissioner
United States Tax Court
By testamentary disposition, decedent granted a life estate in her personal residence to her surviving husband. Upon the termination of the life estate, decedent's executor was directed under the terms of the will to sell the residence and distribute the proceeds to four named charities.
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By testamentary disposition, decedent granted a life estate in her personal residence to her surviving husband. Upon the termination of the life estate, decedent's executor was directed under the terms of the will to sell the residence and distribute the proceeds to four named charities. Held, the disposition in favor of the charities is equivalent to the "contribution of a remainder interest in a personal residence" within the meaning of sec. 170(f)(3)(B)(i), I.R.C. 1954, and, therefore, under sec. 2055(a), I.R.C. 1954, decedent's estate is entitled to a charitable deduction equal to the…
1Opinion of the Court
Estate of Eliza W. Blackford, Deceased, Bank of Charles Town, Administrator, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Blackford v. Commissioner
Docket No. 3212-80
United States Tax Court
77 T.C. 1246; 1981 U.S. Tax Ct. LEXIS 14;
December 8, 1981, Filed
Decision will be entered under Rule 155.
By testamentary disposition, decedent granted a life estate in her personal residence to her surviving husband. Upon the termination of the life estate, decedent's executor was directed under the terms of the will to sell the residence and distribute the proceeds to four named…
2Cases cited12 opinions
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Mosells Silvey Pitner v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- The Miami Beach First National Bank, as Under the Will of Lenore P. Hartz, Deceased v. United StatesCourt of Appeals for the First Circuit · 1971
- Greer v. United StatesCourt of Appeals for the Fourth Circuit · 1971
- Estate of Lapinsky v. SparacinoWest Virginia Supreme Court · 1963
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