Estate of Marine v. Commissioner
United States Tax Court
A codicil to decedent's will provided that his personal representatives, in their discretion, could select and compensate persons who had contributed to decedent's well-being during his lifetime. The codicil limited each such bequest to a maximum of 1 percent of decedent's gross probate estate, without limiting the number of such bequests that could be made. Decedent's will left the residue of his estate to charitable beneficiaries.
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A codicil to decedent's will provided that his personal representatives, in their discretion, could select and compensate persons who had contributed to decedent's well-being during his lifetime. The codicil limited each such bequest to a maximum of 1 percent of decedent's gross probate estate, without limiting the number of such bequests that could be made. Decedent's will left the residue of his estate to charitable beneficiaries. Held, the value of the residue was not ascertainable at the date of decedent's death and thus is not deductible from his gross estate as a transfer to charity…
1Opinion of the Court
ESTATE OF DAVID N. MARINE, DECEASED, WILLIAM H. PRICE, II AND ALICE B. NILY, PERSONAL REPRESENTATIVES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Marine v. Commissioner
Docket No. 26928-88
United States Tax Court
97 T.C. 368; 1991 U.S. Tax Ct. LEXIS 85; 97 T.C. No. 26;
September 23, 1991, Filed
Decision will be entered for the respondent.
A codicil to decedent's will provided that his personal representatives, in their discretion, could select and compensate persons who had contributed to decedent's well-being during his lifetime. The codicil limited each such bequest to a…
2Cases cited30 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- 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
- Humes v. United StatesSupreme Court of the United States · 1928
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