Estate of Edgar v. Commissioner
United States Tax Court
By trust agreements, two sisters created reciprocal revocable inter vivos trusts. According to the terms of decedent's trust, the income was payable to herself for life, and after her death, the income was payable to her sister for life. Upon the death of both sisters, the trust was to terminate. After certain dispositions, the remaining principal of decedent's trust was to pour over to her sister's trust.
Read the full summary
By trust agreements, two sisters created reciprocal revocable inter vivos trusts. According to the terms of decedent's trust, the income was payable to herself for life, and after her death, the income was payable to her sister for life. Upon the death of both sisters, the trust was to terminate. After certain dispositions, the remaining principal of decedent's trust was to pour over to her sister's trust. This latter trust provided that upon the death of both sisters, the trust would terminate. After certain dispositions, the trust provided that from its net income the trust would pay,…
1Opinion of the Court
OPINION
Irwin, Judge:
Respondent determined a deficiency in petitioner’s estate tax of $28,074.21. Due to concessions, the only issue remaining for our consideration is whether petitioner is entitled to a charitable deduction for the value of the remainder interest of a trust which was bequeathed to qualifying institutions (within the meaning of sec. 2055(a)(2)).
All of the facts have been stipulated, and the stipulation of facts is incorporated herein by this reference. At the time the petition was filed herein, Century National Bank & Trust Co., Executor of the Estate of Clara E. Edgar…
2Cases cited2 opinions
- Henslee v. Union Planters National Bank & Trust Co.Supreme Court of the United States · 1949
- Merchants Nat. Bank of Boston v. CommissionerSupreme Court of the United States · 1943
3Cited by17 opinions
- Estate of Boeshore v. CommissionerUnited States Tax Court · 1982
- Estate of La Meres v. Comm'rUnited States Tax Court · 1992
- Estate of Strock v. United StatesDistrict Court, W.D. Pennsylvania · 1987
- Estate of Crafts v. CommissionerUnited States Tax Court · 1980
- Galloway v. United StatesCourt of Appeals for the Third Circuit · 2007
12 more not listed; retrieve them via the Exa API.