St. Louis Union Trust Co. v. Commissioner
United States Board of Tax Appeals
1. Where a bequest for "benevolent purposes" can, consistently with the will, be applied to other purposes than such religious, charitable, scientific, literary or educational purposes as are meant by section 403(a)(3) of the Revenue Act of 1921, there can be no deduction under this section. 2. A bequest to charity upon certain conditions held not deductible under section 403(a)(3). 3. Widow's child's share of husband's estate under Missouri law was properly included in the…
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1. Where a bequest for "benevolent purposes" can, consistently with the will, be applied to other purposes than such religious, charitable, scientific, literary or educational purposes as are meant by section 403(a)(3) of the Revenue Act of 1921, there can be no deduction under this section. 2. A bequest to charity upon certain conditions held not deductible under section 403(a)(3). 3. Widow's child's share of husband's estate under Missouri law was properly included in the gross estate under provisions of the Act, which are not unconstitutional, following Allen v. Henggeler, 32 Fed.(2d) 69.…
1Opinion of the Court
ST. LOUIS UNION TRUST CO. AND BETTIE B. BROWN, EXECUTORS, ESTATE OF GEORGE WARREN BROWN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
St. Louis Union Trust Co. v. Commissioner
Docket No. 12868.
United States Board of Tax Appeals
21 B.T.A. 1201; 1931 BTA LEXIS 2230;
January 16, 1931, Promulgated
1. Where a bequest for "benevolent purposes" can, consistently with the will, be applied to other purposes than such religious, charitable, scientific, literary or educational purposes as are meant by section 403(a)(3) of the Revenue Act of 1921, there can be no deduction under this section.
2…
2Cases cited24 opinions
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- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- United States v. RobbinsSupreme Court of the United States · 1926
- Jones v. HabershamSupreme Court of the United States · 1883
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