Estate of Orphanos v. Commissioner
United States Tax Court
The testator directed in his will that certain property be held in trust and that the income be accumulated until a sufficient amount existed to build a hospital in Kerasitsa, Greece. Upon completion of the hospital the trust was to terminate, the property was to be sold, and the proceeds were to be used to equip the hospital. There were no further directions as to the hospital in the will.
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The testator directed in his will that certain property be held in trust and that the income be accumulated until a sufficient amount existed to build a hospital in Kerasitsa, Greece. Upon completion of the hospital the trust was to terminate, the property was to be sold, and the proceeds were to be used to equip the hospital. There were no further directions as to the hospital in the will. Respondent disallowed the claimed charitable deduction on the ground that the testator's heirs would inherit the hospital. Held, pursuant to Kentucky law we find that the testator's intent was to have a…
1Opinion of the Court
Estate of Peter Orphanos, Deceased, and First Security National Bank & Trust Co., Executor, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Orphanos v. Commissioner
Docket No. 5516-75
United States Tax Court
67 T.C. 780; 1977 U.S. Tax Ct. LEXIS 157;
February 9, 1977, Filed
Decision will be entered for the petitioner.
The testator directed in his will that certain property be held in trust and that the income be accumulated until a sufficient amount existed to build a hospital in Kerasitsa, Greece. Upon completion of the hospital the trust was to terminate, the property was to…
2Cases cited12 opinions
- Trustees Presbyterian Church v. MizeCourt of Appeals of Kentucky · 1918
- Calloway v. CallowayCourt of Appeals of Kentucky · 1916
- Wright v. SingletonCourt of Appeals of Kentucky · 1920
- University of Louisville v. Liberty National Bank & Trust Co.Court of Appeals of Kentucky (pre-1976) · 1973
- Graham v. JonesCourt of Appeals of Kentucky (pre-1976) · 1965
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