Legal Opinion

Hallett v. Commissioner

United States Board of Tax Appeals

Decided December 5, 1933No. Docket No. 60044Published

The decedent bequeathed the residue of his estate to trustees for charitable purposes, with the provision, however, that the trustees "shall make payments for the relief and support" of certain relatives "who, through misfortune, may be in need of such relief, and support."

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The decedent bequeathed the residue of his estate to trustees for charitable purposes, with the provision, however, that the trustees "shall make payments for the relief and support" of certain relatives "who, through misfortune, may be in need of such relief, and support." Held, that the value of the residuary estate at the time of decedent's death, without diminution on account of the contingent interests of the relatives, is deductible in computing the net taxable estate for estate tax purposes.

1Opinion of the Court

E. H. HALLETT, MARTIN A. BROWN, EUGENE M. DOW, AND NELL T. MOULTON, EXECUTORS OF THE ESTATE OF HERBERT B. MOULTON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hallett v. Commissioner

Docket No. 60044.

United States Board of Tax Appeals

29 B.T.A. 494; 1933 BTA LEXIS 934;

December 5, 1933, Promulgated

The decedent bequeathed the residue of his estate to trustees for charitable purposes, with the provision, however, that the trustees "shall make payments for the relief and support" of certain relatives "who, through misfortune, may be in need of such relief, and support." Held, that…

2Cases cited1 opinion

  1. Hallett v. CommissionerUnited States Board of Tax Appeals · 1933

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