Estate of Christiansen v. Comm'r
United States Tax Court
H was the only legatee of her mother's will. H disclaimed the portion of the gross estate that had a fair market value of more than $ 6,350,000. The will provided that any disclaimed portion would pass in part to a charitable foundation and in part to a charitable trust that would pay an annuity to the foundation. H did not disclaim a contingent remainder in the property passing to the charitable trust.
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H was the only legatee of her mother's will. H disclaimed the portion of the gross estate that had a fair market value of more than $ 6,350,000. The will provided that any disclaimed portion would pass in part to a charitable foundation and in part to a charitable trust that would pay an annuity to the foundation. H did not disclaim a contingent remainder in the property passing to the charitable trust. On the estate's tax return, it deducted as charitable contributions the disclaimed property passing to the foundation and -- to the extent of the present value of the annuity interest -- the…
1Opinion of the Court
Holmes, Judge:1
Helen Christiansen’s will left everything to her only child, Christine Hamilton. The will anticipated that Hamilton would disclaim a part of her inheritance, and directed that any disclaimed property would go in part to a charitable trust and in part to a charitable foundation that Christiansen had established. The trust would last for 20 years, and pay an annuity of 7 percent of the corpus’s net fair market value at the time of Christiansen’s death to the foundation. At the end of the 20 years, if Hamilton were still alive, the property left in the trust would go to her.
The…
2Cases cited14 opinions
- Commissioner v. TellierSupreme Court of the United States · 1966
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Ward v. CommissionerUnited States Tax Court · 1986
- Commissioner of Internal Revenue v. ProcterCourt of Appeals for the Fourth Circuit · 1944
9 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
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- Graev v. CommissionerUnited States Tax Court · 2013
- Mohamed v. Comm'rUnited States Tax Court · 2012
- Hendrix v. Comm'rUnited States Tax Court · 2011
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