Longue Vue Foundation v. Commissioner
United States Tax Court
A testamentary charitable bequest was voidable by the exercise of statutory rights of forced heirs under Louisiana law. Held, under the facts of this case and because the forced heirs did not exercise their statutory rights, a charitable estate tax deduction under sec. 2055, I.R.C. 1954, as amended, is allowed for the charitable bequest.
1Opinion of the Court
SWIFT, Judge:
This matter is before the Court on petitioners’ motions for summary judgment and for partial summary judgment filed under Rule 121.1 Respondent objects to petitioners’ motion for summary judgment on the merits of the issue raised therein, and respondent objects to petitioners’ motion for partial summary judgment on the grounds that the issue raised therein is not ripe for summary judgment.
In a statutory notice of deficiency dated December 4, 1984, respondent determined a deficiency in the amount of $9,244,917 in the Federal estate tax liability of the Estate of Edith R. Stern. In…
2Cases cited16 opinions
- Ahmanson Foundation v. United StatesCourt of Appeals for the Ninth Circuit · 1981
- Cox v. Von AhlefeldtSupreme Court of Louisiana · 1901
- Dimock v. CorwinCourt of Appeals for the Second Circuit · 1938
- Bel v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Baten v. TaylorSupreme Court of Louisiana · 1979
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3Cited by4 opinions
- Estate of Marine v. CommissionerUnited States Tax Court · 1991
- Estate of Harvey v. United StatesDistrict Court, E.D. Louisiana · 1988
- Estate of Marine v. CommissionerUnited States Tax Court · 1991
- Longue Vue Foundation v. CommissionerUnited States Tax Court · 1988