Thomas Burdick, Estate of Perrin v. Burdick v. Commissioner Internal Revenue Service

TANG, Circuit Judge:

The estate of Perrin V.' Burdick (“Taxpayer”) appeals the tax' court’s denial of its $60,000 charitable deduction. Taxpayer challenges the tax court’s finding that it terminated the nondeductible split-interest charitable bequest (“split-interest”) solely to gain a charitable, deduction. Taxpayer also argues that when it terminated the split-interest, the split-interest rules no longer applied. We affirm.

BACKGROUND

Perrin V. Burdick (“decedent”) died testate. His holographic will was duly probated in California. Thomas Andrew Burdick (“Andrew”), decedent's brother, was…